An email, October 4, 2016:
Hi can you drive a water tanker in the usa…. Without a purged vehicle certificate ? if tanker is empty ?
My answer that same day:
I am not certain about what other regulations may apply in this case, e.g. those of the Federal Motor Carrier Safety Administration (FMCSA), though I doubt it.
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Easy, yes. But important. So many times I am asked to interpret the regulations of PHMSA/USDOT for the transportation of a certain “Hazardous Material” that turns out not to be a hazardous material at all!
Examples?
- Lubricating or hydraulic oils
- Food grade oils
- Latex (water-base) paints
- Intact fluorescent lamps
- Alkaline batteries
- Non-friable asbestos
- Articles containing oils with low concentrations of PCBs
- More!
What does it mean if an article or substance does not meet the USDOT definition of a hazardous material? Well, it then is not subject to the Hazardous Materials Regulations of PHMSA/USDOT when transported in commerce or offered for transport in commerce. Or, put more simply: not regulated by USDOT.
A non-hazardous material may be subject to the regulations of other regulatory agencies. For example, oils of all types are regulated by USEPA under Clean Water Act regulations.
Before you can determine the applicable regulations for the transport of a hazardous material you must first answer this simple question: Is it a hazardous material?
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Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |