A: Maybe. When discarded, most lithium-ion (secondary batteries) and lithium primary batteries in use today are likely to be hazardous waste due to ignitability and reactivity (D001 and D003, respectively). With the exception of households, the generator of a waste…
Question: Hello, Good afternoon! My name is Jane Doe, I’m from Company’s Regulatory Affairs department and I have been researching hazmat shipping regulations. I understand that orientation arrows are required on two opposite, vertical sides of the package if the…
Question: Hey Daniel, reading over your answered questions on your website and how full and complete you answer questions.My Question: In California CVC 32000.5 states in part ” and a motor carrier who transports for a fee in excess of…
An email received March 21, 2022: Good Afternoon Daniel I am inquiring in regards to the labelling using UN3481. We have a product that requires the UN3481 but also instructed us to use the attached label “Cargo Aircraft Only”. It…
A question about the classification of a waste as a non-hazardous industrial solid waste in Texas on Mar 8, 2022, 12:09 PM: Daniel, Thank you for the assistance on the UW issues I asked about in February of this year.…
The contingency plan is just one very important part of the many responsibilities of the large quantity generator of hazardous waste (LQG) subject to the regulations of 40 CFR 262, Subpart M for Preparedness, Prevention, and Emergency Procedures. Not sure…
Question (03.17.21): Hi Daniel, We have a customer who wants to ship empty containers to a container cleaning center. The totes and drums are empty and have been rinsed. Those containers had hazmat materials, can they cover up the labels…
A question on 01.29.21: Hi Daniel, Have a project I am running from Mahwah, NJ to Philadelphia, PA. It was my understanding that if the total weight of the hazardous material was under 1,000lbs then it did not require a…
Question (12.08.20): Hi Daniel, I enjoy reading your articles, find them concise and easy to interpret. I was reading your piece on the government employee exemption, and wanted to get your opinion on something. Since the word “commerce” seems to…
The conditions of the empty packaging exception at 49 CFR 173.29 include the terms “contract or private carrier”. Despite the importance of these terms to this exception and their use elsewhere in the Hazardous Materials Regulations (HMR) of USDOT/PHMSA, nowhere…
