Daniels Training Services

Non-Routine Shipments of Hazardous Materials

Non-Routine Shipments of Hazardous Materials

“Other than hazardous waste, we don’t ship hazardous materials, so we don’t need the DOT HazMat Employeetraining for our Shipping Department personnel.”   The preceding statement may be true when its ‘business as usual’, but there are a few situations that arise not infrequently in business that may require you to prepare a ‘one-time’ hazardous material for shipment.  A ‘one-time’ shipment is subject to the entire Hazardous Materials Regulation (HMR) – including training of HazMat Employees – so it’s important to be prepared for any of the following situations:

  1. A hazardous material received as product (paint, cleaner, solvent, plating solution, reactant, epoxy, etc…) must be returned to the supplier. Perhaps the product you received was the wrong color, off-spec, in excess of your needs, or in some other way was not what you wanted and must now be returned to the supplier.  In most cases, returning the material in the original packaging with the original shipping paper will suffice to meet most requirements of the HMR.  However, these items may not always be available.  And, in this case you are the Shipper and therefore responsible for any errors in the shipment, regardless if the same error was made by the entity that shipped it to you.
  2. A customer requires a small amount of your raw material – such as paint – to “touch-up” a product of yours they have received. Typically you receive your product as hazardous materials in quantities ranging from 5-gallon buckets to bulk containers.  A customer request may be for much smaller amounts.  How must the hazardous material be packaged?  What are the shipping paper requirements?  Are there exemptions to the HMR for this type of shipment?  You must be certain of the applicable regulations before you can meet your customer’s request.
  3. A ‘sister facility’ requires some proprietary material you have in stock. If you are offering a hazardous material for shipment in commerce, even if that shipment is across the street, that shipment will be subject to the full HMR unless specific exemptions apply.

Any one of these situations may arise without warning and require a rapid response.  Therefore it’s best to be prepared ahead of time.  HazMat Employee training presented by Daniels Training Services will provide you with three things: