PO Box 1232 Freeport, IL 61032

A Different Kind Of Training

A Different Kind Of Training

A Different Kind Of Training

April/May 2014– Rules & Regulations, Proposed Rules, and Notices Regarding the Management of Hazardous Waste and the Transportation of Hazardous Materials

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA), Federal Railroad Administration (FRA), Federal Motor Carrier Safety Administration (FMCSA) and the Federal Aviation Administration (FAA) of the US DOT on the subject of Transportation of Hazardous Materials.

The Federal Register is a great way to look down the road and see potential changes to the regulations long before they are put into effect (sometimes The Rulemaking Process takes years before a final rule is issued, if ever).  Knowledge of these potential changes provides you with several advantages:

  • Additional time to modify your business operations to comply.
  • Awareness of on what topics the regulatory agencies intend to focus their efforts.
  • The ability to register your concerns, complaints, suggestions, etc. in order to modify the proposed rule before a final rule is issued.  It can be done, really!
  • Make changes to your training program to account for changes that become effective before the next training cycle.
  • Alert you to the need to re-train your employees prior to their next scheduled training cycle, if necessary.
  • Keep you abreast of changes to the regulations that affect your business and/or your industry group.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance.

April 15, 2014 through May 29, 2014

PHMSA – Pipeline and Hazardous Materials Safety Administration:

Rules and Regulations:

None

Proposed Rules:

None

Notices:

  • New York City Permit Requirements for Transportation of Certain Hazardous Materials Pages 21838 – 21840 [FR DOC # 2014-08691]        PDF | Text | More
  • Pittsburgh, Pennsylvania Permit Requirements for Transportation of Hazardous Material Pages 21840 – 21842 [FR DOC # 2014-08690]       PDF | Text | More
  • Notice of Applications for Modification of Special Permit Pages 25987 – 25988 [FR DOC # 2014-10071]        PDF | Text | More
  • Notice of Application for Special Permits Pages 25988 – 25989 [FR DOC # 2014-10073]      PDF | Text | More
  • List of Special Permit Applications Delayed More Than 180 Days Pages 25989 – 25990 [FR DOC # 2014-10069]       PDF | Text | More
  • Special Permit Applications Pages 25994 – 25995 [FR DOC # 2014-10070]       PDF | Text | More
  • Recommendations for Tank Cars Used for the Transportation of Petroleum Crude Oil by Rail Pages 27370 – 27371 [FR DOC # 2014-10914]         PDF | Text | More
  • International Standards on the Transport of Dangerous Goods Pages 30689 – 30690 [FR DOC # 2014-12238] PDF | Text | More
FRA – Federal Railroad Administration:

Rules and Regulations:

None

Proposed Rules:

None

Notices:

  • Recommendations for Tank Cars Used for the Transportation of Petroleum Crude Oil by Rail Pages 27370 – 27371 [FR DOC # 2014-10914] PDF | Text | More
FAA – Federal Aviation Administration:

Rules and Regulations:

None

Proposed Rules:

None

Notices:

None
USEPA – US Environmental Protection Agency:

Rules and Regulations:

None

Proposed Rules:

  • Hydraulic Fracturing Chemicals and Mixtures Pages 28664 – 28670 [FR DOC # 2014-11501]        PDF | Text | More

Notices:

  • Santa Fe Springs Drums Site, Santa Fe Springs, CA; Notice of Proposed CERCLA Settlement Agreement for Recovery of Past Response Costs Pages 23352 – 23352 [FR DOC # 2014-09575] PDF | Text | More
  • Proposed CERCLA Administrative Cost Recovery Settlement; Absorbent Technologies Site, Albany, OR Pages 26961 – 26961 [FR DOC # 2014-10844] PDF | Text | More
  • Chemfax Inc. Superfund Site; Gulfport, Harrison County, Mississippi; Notice of Settlement Pages 26962 – 26962 [FR DOC # 2014-10804] PDF | Text | More

Information can be helpful but it’s useless if you are not able to make sense of it.  You must be able to determine how any changes to the rules and regulations (final or proposed) will affect your operations, and communicate the necessary information to your personnel.  I can help you to do that.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

Please contact me for a free training consultation to determine your regulatory requirements and how training can help you to attain and maintain compliance with the regulations of the USEPA (and your state) and the PHMSA/USDOT.

The Description of Special Permits (aka: Exemptions) on a Hazardous Materials Shipping Paper per 49 CFR 172.203(a)

Hey! What’s on That Truck? Identification of Hazardous Materials in Transportation

One thing about hazardous materials that can’t be denied is that they move among us all the time.  It’s the proximity of hazardous materials in commerce to people that makes adherence to the Hazardous Materials Regulations so important.  Since we find hazardous materials in transportation around us frequently, it behooves us to learn more about them and the hazard communication methods.  Take a look at the photo below and see if you agree with my interpretation of the regulations. (more…)

The De Minimis Exception From the Hazardous Materials Regulations

The transportation in commerce of a hazardous material is usually subject to the Hazardous Material Regulations (HMR) of the USDOT/PHMSA.  However, the transportation of certain hazardous materials, below specified thresholds, in authorized packaging may receive an exception from full regulation.  And, in some cases, the hazardous material may be fully excepted from regulation under the HMR.  Just such a case of a full exception is the De Minimis Exception, found at 49 CFR 173.4b and summarized below. (more…)

What’s Wrong With This Picture? Errors Made by Shippers and Carriers of Hazardous Materials

We all make mistakes.  But when it impacts compliance with the Hazardous Material Regulations (HMR) of the USDOT/PHMSA, a mistake can be costly and dangerous.  And since hazardous materials in transportation are so frequently in public view, violations of the HMR can be detected by anyone familiar with the regulations.  So… (more…)

March/April 2014– Announcements of Proposed Rules, Changes to the Rules, and Final Rules for RCRA and the HMR

Federal Register:  The Daily Journal of the United States Government
The Federal Register is a communication tool used by the US Government.

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA) of the US DOT on the subject of Transportation of Hazardous Materials.

The Federal Register is a great way to look down the road and see potential changes to the regulations long before they are put into effect (sometimes The Rulemaking Process takes years before a final rule is issued, if ever).  Knowledge of these potential changes provides you with several advantages:

  • Additional time to modify your business operations to comply.
  • Awareness of on what topics the regulatory agencies intend to focus their efforts.
  • The ability to register your concerns, complaints, suggestions, etc. in order to modify the proposed rule before a final rule is issued.  It can be done, really!
  • Make changes to your training program to account for changes that become effective before the next training cycle.
  • Alert you to the need to re-train your employees prior to their next scheduled training cycle, if necessary.
  • Keep you abreast of changes to the regulations that affect your business and/or your industry group.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance. (more…)

The Shipper’s Certification on a Hazardous Materials Shipping Paper

The transportation in commerce of a hazardous material will require a description of the HazMat on a shipping paper unless an exception is identified in 49 CFR 172.200(b).  Pursuant to 49 CFR 172.204, the HazMat shipping paper must include a certification by the shipper that the hazardous material offered for transportation is in compliance with all applicable regulations.  The purpose of this article is to describe the requirements for the shipper’s certification on a shipping paper for the transportation in commerce of a hazardous material. (more…)

Correcting Mistakes on a Uniform Hazardous Waste Manifest

Everybody makes mistakes, right?  But what if those mistakes are made by a generator of hazardous waste on the uniform hazardous waste manifest?  In this article I will explain the regulatory requirements of both the USEPA and the USDOT/PHMSA for correcting mistakes on the uniform hazardous waste manifest (Manifest). (more…)

Who is a HazMat Employer?

The safe transportation of a hazardous material, which includes the time it is loaded or unloaded from a vehicle on your property, requires knowledge of the Hazardous Material Regulations of the PHMSA/USDOT.  This knowledge can come from a variety of sources, but only one is required by the very regulations themselves:  TRAINING.  49 CFR 171.702(a) mandates a HazMat Employer to ensure that each of its HazMat Empoyees is trained and tested according to §172, Subpart H; this means:

49 CFR 172, Subpart H requires training for all HazMat Employees
Are you the HazMat Employer who rented this truck?
  • Initial training within 90 days of employment or applicable activities.
  • Supervised by trained and knowledgeable personnel prior to receiving training.
  • Full recurrent training within three years.
  • Prescribed HazMat Employee training content:
    • General Awareness/Familiarization
    • Function Specific
    • Safety/Emergency Response
    • Security General Awareness
    • In-Depth Security (if applicable)
  • HazMat Employees must be tested.

A later article will look more closely at the identification of a HazMat Employee.  Since all of this is the responsibility of the HazMat Employer, it is imperative that this term is understood first. (more…)

February/March 2014 – Announcements of Proposed Rules, Changes to the Rules, and Final Rules for RCRA and the HMR

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA) of the US DOT on the subject of Transportation of Hazardous Materials.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance. (more…)

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