If the applicable regulations mandate you provide training for you and/or your personnel you may wish to consider a web-based training format (webinar training) to deliver that training. Below are some frequently asked questions about my webinar training.

1. Is your webinar training just a pre-recorded message?
   • No.  Webinar training is delivered live.  You will be able to see the training presentation and hear the trainer’s (me!) voice in real time.
2. Will the training content be specific to my operations and what my employees need to know?
   • Yes.  Webinar training can be tailored to your needs to include just the content you require.  For example, if you do not ship HazMat by rail, webinar training won’t address the regulations of 49 CFR 174 – Carriage by rail.

     

3. What if I or one of my personnel have a question during the webinar training?
   • Trainees may ask questions and have them answered during the webinar training.  Trainees may type a question directly to me or simply speak up.  I can pause training, go back over critical information, clarify content, and even provide additional information that is not part of the training presentation.  I also provide unlimited time at the conclusion of the webinar training for questions.
4. Due to concerns about COVID-19, I am unable to gather personnel in one location.
   • No problem.  My webinar training platform (GotoMeeting) allows for up to 25 separate log-ins.  Trainees can attend the webinar training from home or private office.
5. Due to concerns about COVID-19, most personnel are working from home.
   • No problem.  Trainees can attend the webinar training from any location with an internet connection and a telephone.  Up to 25 separate log-ins are allowed for each webinar training.

   • Interested in a Webinar? My Webinar Training Schedule

6. We have a widely-dispersed work-force with locations throughout the U.S.
   • No problem.  Trainees can attend the webinar training from anywhere in the U.S. (anywhere in the world, really).  Any place that has an internet connection and phone service can be a full participant in my webinar training.

     

7. If personnel attend the webinar training from home or private office, how do I ensure they are present and attentive throughout?
   • Attendance and attentiveness are a challenge for any training format.  My webinar training has several ways to ensure trainees actually get something of value from the time spent.  This includes:
     • I provide recordkeeping documents for trainees to complete and provide to the responsible person (i.e., training coordinator).
     • Trainees must log-in to the webinar and display their name.
     • The webinar platform (GotoMeeting) allows for video conferencing so each trainee can be seen.  (This is an option).
     • Training will include a test at the conclusion.
     • Training may include a series of questions throughout the presentation to require trainees to engage in and interact with the content.  Trainee answers to the questions are submitted to the responsible person.
8. How many personnel can attend webinar training?
   • There is no limit on the number of trainees.  Cost (see below) is a flat fee and is not affected by the number of trainees.
9. When can I schedule webinar training?
   • Any time day or night is OK for webinar training.  Webinar training may be scheduled on a Saturday, but not a Sunday.  Additional fees may apply to training held outside of normal business hours.

   • Interested in a Webinar? My Webinar Training Schedule

10. What if some of my personnel miss the scheduled date and time of the webinar training?
    • I can create a recording of the webinar training and make it available for a fee.  This recording can be viewed as a movie by personnel at any time.
11. May I speak directly to my personnel during the webinar?
    • Yes.  I am able to ‘share the mic’ with you at any point during the webinar training if you wish to speak directly to trainees.
12. What if I have questions after the webinar training has concluded?  Perhaps days, weeks, or months later?
    • No problem.  Feel free to contact me any time with questions.
13. What if I require specialized training such as for lithium batteries, loading or unloading cargo tanks, filling IBCs, &etc.?
    • Once you decide on site-specific webinar training I will send you a Questionnaire I have developed to gather information about your operations.  I will then create a site-specific training presentation.  Specialized training is part of the webinar training I provide.
14. What does your webinar training cost?
    • That depends on the content (see below) and delivery options (see belower).  Below are cost guidelines for site-specific training delivered at a date and time of your convenience:
      • Four (4) hours: $999.
      • Six (6) hours: $1,249.
      • Eight (8) hours: $1,749
      • Twelve (12) hours: $1,999
      • Sixteen (16) hours: $2,499
    • Costs are lower for webinars that do not provide site-specific content, i.e., Public Webinar or Scheduled Webinar (see below).
    • All webinar training costs are a flat fee.  There are no additional costs for printing, travel, number of log-ins (up to 25), or number of trainees (unlimited).
15. What if copies of the applicable regulations are necessary for the webinar training?
    • If copies of the regulations are necessary they can be purchased by the customer (I can provide purchase options) or I can provide copies to use during the webinar training for a fee.

    • Interested in a Webinar? My Webinar Training Schedule

16. What training content does Daniels Training Services offer?
    • HazMat Employee Training required by the U.S. Department of Transportation (DOT).
    • Hazardous Waste Personnel (RCRA) Training required by the U.S. Environmental Protection Agency (EPA) and states with an authorized hazardous waste program.
    • IATA Dangerous Goods Training for shippers and packers of dangerous goods by air required by the International Air Transport Association (IATA).
    • IMO Dangerous Goods Training for international shippers (shore-based personnel) of dangerous goods by vessel required by the International Maritime Organization (IMO).
17.  What are my options for webinar training?
    • Public Webinar – These are regularly scheduled (1/month) webinars that meet the training requirements for either HazMat Employees or  Hazardous Waste Personnel.  As they are open to all they are general in content and not site specific.  This is a good option for those wishing to fulfill the training requirements for themselves and/or a small number of employees at the least expense.  My Public Webinar Training Schedule.
    • Site-Specific Webinar – This webinar is scheduled at your convenience.  I will work with you to ensure the training addresses the Federal and State regulations that impact your operations.  There is no limit to the number of trainees who participate, you may even include off-site locations.  This training option is the best way to receive site-specific training with the least expense and disruption to your operations.
    • Scheduled Webinar – This webinar combines the best features of the Public Webinar and the Site-Specific Webinar.  If you are satisfied with the content of a Public Webinar but have many people to train and/or a schedule conflict, you may wish to consider a Scheduled Webinar.  This training helps you to meet the regulatory requirements for all of your employees at a time and date of your convenience.  There is no limit to the number of trainees or off-site locations you may include.
18. What if I have other questions?
    • Contact me!

    • Interested in a Webinar? My Webinar Training Schedule

In response to COVID-19, the Wisconsin DNR is aware that facilities may need additional time to complete and submit their annual reports.

The 2019 hazardous waste annual report was due March 1, 2020, per ss. NR 662.041(1) Wis. Adm. Code. While this regulatory requirement does not specifically allow for extensions to this deadline, it is understood that between the delayed launch of the report and current workforce limitations due to COVID-19, facilities may need additional time to complete the report. We do encourage generators to complete and submit the report as soon as possible, to allow for the department to submit the required reporting data to the U.S. EPA in a timely fashion.

• Hazardous waste annual report webpage

A large quantity generator of hazardous waste (LQG) must provide intial training for all hazardous waste personnel with an annual review of the inital training.  I can provide this training.  If Onsite Training is not possible right now, how about a webinar?  Advantages to web-based training:

• Same content as my Onsite Training.
• Webinar is live, interactive, and – with your assistance – can be made site-specific.
• I provide all the necessary documents for training, testing, and recordkeeping.  All documents emailed to you prior to the webinar.
• Low cost and easy to schedule.
• Up to 25 separate log-ins (no need to gather trainees in one place). Unlimited number of trainees.

In response to COVID-19, the Wisconsin Department of Natural Resources has developed an online method for requesting an extension to generator accumulation time limits.

Wisconsin’s hazardous waste regulations allow both large quantity generators (LQG) and small quantity generators (SQG) to request an accumulation (storage) time limit extension in the event of unforeseen, temporary or uncontrollable circumstances that prevent shipment of hazardous waste off-site within the 90-day time frame (LQGs) and or 180-day time frame (SQGs). An extension of up to 30 days may be granted at the discretion of the department on a case-by-case basis pursuant to s. NR 662.034(3) and NR 662.192(3), Wis. Adm. Code.

A request for an extension must be made prior to the expiration of the required time limit. Potential reasons for requesting an extension must be identified to submit a request (i.e., transporter unable to meet schedule shipping date, or scheduled facility unable to accept wastes due to facility backlog or closure). To request an extension, follow the link below to submit your information to the DNR electronically. You can also contact a regional hazardous waste specialist, or Hazardous Waste Program Coordinator Mike Ellenbecker, to submit a request directly to program staff.

2020 Hazardous Waste Storage Facility Accumulation Time Extension Request

If a 30-day extension request is granted but the hazardous waste shipment the extension was requested for cannot occur within the extended period, contact Hazardous Waste Program Coordinator Mike Ellenbecker to discuss the regulatory requirements.

Annual Hazardous Waste Personnel training for large quantity generators of hazardous waste must still be completed. Contact me to schedule a webinar during the shelter-in-place.

It’s changed over the years, but here is what I found from The United States Government Manual 1991/92:

The purpose of the Environmental Protection Agency is to “protect and enhance our environment today and for future generations to the fullest extent possible under the laws enacted by Congress.  The Agency’s mission is to control and abate pollution in the areas of air, water, solid waste, pesticides, radiation, and toxic substances.  Its man date is to mount an integrated, coordinated attack on environmental pollution in cooperation with State and local governments.”

Question:

Hello,

I am employed with (working to become a contract driver soon) with a company that services nursing homes with oxygen cylinders. They provide various sizes of cylinders and also provide filling of liquid oxygen for reservoirs on-site. I carry well over 1001 lbs. on my route.

My question is, why is my truck placarded non-flammable gas 2 ?????

and not oxygen 2?????

I can’t get a straight answer from my management and was curious if you could help. Also, is there training you provide online that would help me?

Thanks,

My reply:

Thank you for contacting me.  Please see below.

Just a quick question June 19, 2018:

Is carrying 40 – 55 gallon drum of NaOH on a box trailer considered bulk?

Sent from my iPhone

My reply just an hour later:

No it is not.

Please see below for an explanation:

• A bulk packaging is one with a capacity of greater than 119 gallons. Read: Bulk Packaging for HazMat Explained!
• Your containers are 55 gallons each.
• The total volume of the shipment is not a factor.
• You may, however, need to display the identification number for the hazardous material on the vehicle.
  • Read:  Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings
  • Read: Display of the Identification Number on Transport Vehicles and Freight Containers

Her gracious reply:

Thank you. That’s what I thought but just wanted to make sure.

I wasn’t done (I have so much to share!):

You’re welcome!

You may wish to read this article I wrote indicating when it is necessary to display the identification number on a transport vehicle if it contains a large quantity of a single HazMat:  Vehicle Marking Requirements for Single HazMat.

That spurred another question (06.20.18):

I read the other article you sent and it did clear up when to use numbered placards on a straight forward shipment. Other scenarios would also be helpful.

• What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?
• Same scenario but you picked them up from two separate shippers?
• Another:  Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?

My reply the next day:

I will attempt to answer your questions below.

A follow-up question from a occasional contact (06.13.18):

Daniel, Hope all is doing well.

I have another question that has been bothering me as well.  Hoping you can share some guidance.

Say I have a shipment of UN1993 BULK(ONE TOTE BIN)

I also have a shipment of Corrosive UN1806 non-bulk weighing 500lbs.

No other hazmat on board.  How would this trailer be placarded?

I, myself would say a bulk UN1993 placard and a corrosive placard.

I have had other safety officials advise that the bulk shipment is not included on the aggregate gross weight once its placarded.

My reply several days later:

I have an answer and it is not what I initially anticipated (I’m glad I did additional research of 49 CFR 172.504(c)).  Please see below.

Found at 49 CFR 172.504(e) of the USDOT/PHMSA Hazardous Materials Regulations (HMR), the placarding tables (Table 1 and Table 2) identify a distinction made by USDOT/PHMSA between the “really nasty” hazardous materials of Table 1 and the “routine” HazMat of Table 2.  A HazMat’s location on one of the two tables will play a significant role in determining which – if any – placards are required to be displayed on the vehicle transporting it.  The Table 1 and Table 2 placarding tables are also referenced in the following regulations of the HMR:

• The applicability of the empty packaging (with residue) exception at §173.29(c).

So, what are the Table 1 and Table 2 placarding tables of 49 CFR 172.504(e)?

Table 1:

Table 2:

A question from a frequent customer of mine (06.19.18):

Hi Daniel.

I have a question regarding Universal Waste Lamps that I’m wondering if you have an experience with, and that is light-emitting diodes or LED bulbs. From the reading I have done, it sounds like the EPA wants me to run a TCLP on a bulb to see if it is hazardous, before determining if it can be handled as a Universal Waste lamp.

Would you agree with that assessment or have any input on the subject from your experience?

Thanks for your help.

My reply that same day: