Known by many names, but referred to in the Hazardous Material Regulations at 49 CFR 172.802 as a Security Plan; it is a requirement for certain shippers and carriers of hazardous materials. An earlier article explained the regulatory process @…
What Does RCRA Mean by a Commercial Chemical Product?
The phrase “Commercial Chemical Product” is used in two critical positions in the hazardous waste regulations of the USEPA. In either position it may play an important role in your Hazardous Waste Determination which is required by 40 CFR 262.11 for…
Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings
Generally, one can assume that the use of the Identification Number in association with the placard for a shipment of a hazardous material is limited to those shipments that are or contain a bulk packaging. Such as: The transport vehicle…
The Recordkeeping Requirements for Generators of Hazardous Waste: Training
The regulations of the Resources Conservation and Recovery Act applicable to generators of hazardous waste, codified at 40 CFR 262-268 mandate the creation of a variety of reports, inspection logs, notifications, certifications, manifest, records, etc. In order to demonstrate compliance…
Making RCRA Records “Available” for State and Federal Inspectors
The requirements for generators of hazardous waste to create documents as a part of compliance with the hazardous waste regulations can be found throughout the RCRA regulations. Similarly, the requirements to maintain a copy of those documents as a record…
The Requirements of 40 CFR 265.30 Applicability for Generators of Hazardous Waste
Most generators of hazardous waste must comply with the requirements of 40 CFR 265.30 through 265.37 (aka: Subpart C of Part 265). However, they may not realize these regulations apply to their operations or lack a firm grasp of what…
Safety and Security Plans and In-Depth Security Training Required by the US DOT for Shippers and Carriers of HazMat
An often overlooked or misunderstood component of the Hazardous Material Regulations (HMR) is the requirement for a shipper or carrier of a hazardous material to comply with the regulations at 49 CFR 172, Subpart I which require a Safety and…
Use of Placards on Non-Bulk Packagings of Hazardous Material
Unless an exception to the Hazardous Material Regulations (HMR) is available, every shipment of a hazardous material will require the use of each of the four hazard communication methods of the US DOT, they are: Shipping papers Placards HazMat labels…
The Responsibility for Training and Testing of HazMat Employees
A question I am frequently asked is, “Will you certify my HazMat Employees have been trained?” or, “Do you provide HazMat certification for HazMat Employees?” or some variation on this theme. My answer, unfortunately, does not always satisfy my potential…