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Daniels Training Services Blog

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Q&A: Must a Shipper Provide a Copy of the Special Permit to the Carrier When Applicable?

A question received through my website (Contact me) on March 16, 2016: In addition to the DOT-SP number being listed on the hazmat shipping paper, are you also required to send a copy of the DOT-SP with the hazmat shipment?

Q&A: Hazardous Waste (Aerosol Cans) in an Office Environment

First contact March 15, 2016: Daniel, Do empty aerosol cans that are generated in an office environment have to be treated the same as if they were generated in a manufacturing environment? We generate empty aerosol cans in our manufacturing

12 Ways for Hazardous Waste Generators to Avoid Compliance Problems and Minimize Liability

OK,  full disclosure:  The following list borrows heavily from The Hazardous Waste Generator's Handbook created by the Kansas Department of Health and Environment (KDHE).  I highly recommend it to any Kansas business that requires an introduction to the state regulations

The Specification Packaging Marking Requirements of 49 CFR 178.3

Most packagings intended for the transportation in commerce of a hazardous material must be designed, manufactured, and tested to meet either a DOT specification or a UN standard, which is then known as a specification packaging (Don't confuse "specification packaging"

What’s Wrong with this Picture? Marking on a Hazardous Waste Container per 40 CFR 262.32(b)

Hazardous Waste Container

It's quite simple, really.  USEPA regulations at 40 CFR 262, subpart C require the generator of a hazardous waste to prepare it for off-site transportation according to both USEPA and USDOT/PHMSA regulations. Read all about it here:  USEPA Requirements for

Q&A: Display of Placard on the Headache Rack of a Truck

Commercial motor vehicle with headache rack

This question came to me through my Facebook page on June 15th: I found your website on Google. I have a question that I couldn't find an answer to. I know hazmat placards must be visible from all 4 directions

When the Marine Pollutant Mark is not Required

The purpose of this article is not to identify and explain a marine pollutant as regulated by the Hazardous Material Regulations of the PHMSA/USDOT; you can read all about that here:  What is a Marine Pollutant?  But, a brief summary

Q&A: Transporting Lead Acid Batteries for Reclamation as a Material of Trade

Liquid lead acid battery

A former coworker contacted me with a question on January 29, 2016: I have a quick question for you Dan.  If a facility has 5 - 6 consumer (car type) lead-acid batteries that they want to take to a salvage

Q&A: Transporting an Infectious Substance (Division 6.2) in a Personal or Company Vehicle

I received this email January 25th from a customer who had attended one of my Training Seminars in the past: Dan, How have you been? You said to contact you if we have any questions. I was asked a question

Conditional Exclusion at 40 CFR 261.4(a)(20) for Zinc-Bearing Hazardous Secondary Materials Used to Make Zinc Fertilizer

Though a small part of overall fertilizer production in the U.S., the reclamation of zinc from what would otherwise be discarded as a solid waste - if done correctly - can result in a substantial benefit to the environment.  Below

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