A question during the summer of 2018 (07.24.18): Daniel, I am emailing you in reference to your article from 2015 on Package Orientation Arrows on HazMat Packaging: https://danielstraining.com/package-orientation-arrows-on-hazmat-packaging/ Is there any instructions on the requirements for these arrows/labels? Meaning does this…
The Hazardous Waste Determination Under the Generator Improvements Rule
A generator of hazardous waste must conduct a hazardous waste determination for all solid waste it generates. This requirement is codified in federal regulations at 40 CFR 262.11. A solid waste is defined and explained at 40 CFR 261.2, but…
Comparison of Changes to the Hazardous Waste Determination Regulations Made by the Generator Improvements Rule
In another article I review in detail the federal USEPA regulations of 40 CFR 262.11 and its requirements to conduct a hazardous waste determination as those regulations were changed by the Generator Improvements Rule. Read: The Hazardous Waste Determination Under…
Q&A: Does the De Minimis exception apply to Division 6.1, Packing Group I Poisonous Materials?
Sometimes the questions I receive challenge me to re-visit older articles and dig deeper into the regulations. Like this one from November 23 of 2017: Dear Mr. Stoehr, I saw the piece you wrote on applicability of “De Minimis quantities”…
Q&A: Do I need special paperwork that shows my truck has been cleaned and washed before transporting?
A question I received back on November 17, 2017: I have a company that wants me to haul a used fuel truck that has hauled gas and diesel fuel they say it has been empty and setting in a storage…
Q&A: When does a spill or leak become ‘reportable’?
An interesting aspect of a business like mine is its international application. This question came from a university professor in South America. Hi Daniel. In a group of Hazardous Materials from emergency services a friend ask this: “Seeking some guidance…
FAQ: What is a representative sample?
A generator of a hazardous waste must conduct a hazardous waste determination in order to ensure its wastes are properly managed. This determination may be conducted using solely generator knowledge of the waste and the process of generation or it…
Q&A: Do the IATA Dangerous Goods Regulations allow for the display of “MISCELLANEOUS” on the Class 9 label?
A question from half a world away on November 11, 2017: Hi Daniels Training Services I’m <<Name>> from Vietnam. My company has used DG hazard label – class 9 Miscellaneous with word (there is word “Miscellaneous”) shipment of battery UN3480,…
Q&A: Do I need a purge ticket for my cargo tank?
A question from November 12, 2017: Hello, I just bought a tanker trailer and the seller said it was last used to haul non hazmat. The companies that want to transport it to me are asking for a wash ticket…
FAQ: What is a large packaging?
If you are a shipper of hazardous materials (HazMat) you are subject to the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). The HMR identify a variety of packagings…