# Daniels Training Services

> I'll answer your questions about hazardous waste and HazMat Transportation


## Posts

- [FAQ: What is Adequate Instruction?](https://danielstraining.com/faq-what-is-adequate-instruction/): The Quick Answer: Adequate instruction is an alternative to full regulatory training for persons who prepare certain lithium cells or batteries for transport by aircraft. The requirement to provide adequate instruction is found in the applicable packing instructions of the IATA Dangerous Goods Regulations. Summary: Section II of the lithium battery packing instructions, PI 966, PI 967, PI 969, and PI 970, include a requirement that “Any person preparing or offering cells or batteries for transport must receive adequate instruction on these requirements commensurate with the functions for which they are responsible”. The packing instructions however do not define or […]
- [Q&A: What hazard communication (marks, labels, & placards) are required on a bulk packaging and a vehicle transporting a bulk packaging?](https://danielstraining.com/is-a-55-gallon-drum-weighing-882-lb-a-bulk-packaing/): Question1: If I have a single 55 gallon drum that weighs over 882 is it considered a bulk… Hold it right there! Answer1: In an earlier article I addressed the false premise contained in that first question and explained that the packaging described (55-gallon drum) is not a bulk packaging and is violation of the HMR if it has a maximum net mass of more than 882 lbs; I suggest you read that article first (Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?). In this article I’ll answer the remaining questions poased as if […]
- [Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?](https://danielstraining.com/is-a-55-gallon-drum-weighing-882-lb-a-bulk-packaing-2/): Question: If I have a single 55 gallon drum that weighs over 882 lb is it considered a bulk Wait! Stop! That question contains a false premise. I can’t consider the next question until I explain a bulk packaging and the limits on the maximum net mass of a 55-gallon  drum. The next question will have to wait for another article. Answer: Thank you for contacting me. Please allow me to provide some clarification on the term “bulk packaging”. A bulk packaging is defined at 49 CFR 171.8 in the Hazardous Materials Regulations (HMR). It reads in part: …a bulk […]
- [Q&A: Is my auto shop wastewater an F-listed hazardous waste?](https://danielstraining.com/is-my-auto-shop-wastewater-an-f-listed-hazardous-waste/): Question: I have a question regarding haz waste determination specifically about applicability of F-listed waste. Situation I have: In the car repair shop floor, we have a small pit that collects water (rainwater/snow melting from cars and every now and then hosing the floor down with just water, no soap, solvent or degreaser). We had collected that water from the pit into a 55 gallon drum (only about 3/4 full) and tested it through a laboratory for disposal. But surprisingly there was 14.3 PPM acetone and 0.09 Toluene from VOC TCLP test. We are guessing this is maybe from some […]
- [FAQ: What are the F-listed solvents?](https://danielstraining.com/what-are-the-f-listed-solvents/): The USEPA regulations for the determination of a listed hazardous waste from non-specific sources (F001 – F039) are at 40 CFR 261.31. Waste codes F001 – F005 represent spent organic solvents that are a listed hazardous waste under certain conditions. For a full explanation of the hazardous waste determination for spent organic solvents (F001 – F005), read this article: F-Listed Spent Solvent Hazardous Waste This article will identify the solvents that are possible to be an F-listed hazardous waste as a spent organic solvent. Here they are: Contact me with any questions you may have about the generation, identification, management, […]
- [Q&A: What do I do with a Marine Pollutant in a non-bulk packaging?](https://danielstraining.com/marine-pollutant-in-non-bulk-packaging/): Question1: Good Afternoon Daniel, Our company recently noticed some label changes on a product we use and sometimes ship to our customers. Recently, we’ve begun seeing a class 9 UN3077 label as well as a “marine pollutant” pictogram. I’m aware of the marine pollutant exception in 49CFR 171.4 (c) that states non bulk packages are unregulated unless offered for vessel transport (i.e. on land) The product in question comes in 5 gallon pails, and weigh ~50 lbs. The product is defined as a “solid” by the manufacturer. My question is, is the “non-bulk” receptacle weight of 882 lbs per “bucket” […]
- [Q&A: Does the transport of 55-gallon drums containing the residue Class 3 Flammable Liquid require a HazMat Endorsement on the driver's CDL?](https://danielstraining.com/qa-does-the-transport-of-55-gallon-drums-containing-the-residue-class-3-flammable-liquid-require-a-hazmat-endorsement-on-the-drivers-cdl/): Question: Subject: Empty class 3 flammable drums Message Body: Carry 8 to 12 class 3 flammable drums back to yard to get refill small amount of product still in drums drums mark small flammable sticker do I need hazmat on my license. Answer: Thank you for contacting me. I will try to answer your question below. More information would be helpful, but I think I can confidently answer: No. You do not require the HazMat endorsement on your CDL for the transport of packagings containing the residue of a HazMat; in this case a Class 3 Flammable Liquid. The reason: […]
- [Q&A: Can we print our own HazMat labels? Specifically, the Class 9 Lithium Battery label?](https://danielstraining.com/qa-can-we-print-our-own-hazmat-labels-specifically-the-class-9-lithium-battery-label/): Question: Good morning I was on your web site looking for some information as it pertains to application of the class 9 lithium battery. My questions is do we have to buy labels and hand apply it or can we direct flexo print the diamond to spec. we print a lot of UN Corrosive diamonds on corrugated and I would like to do so with this class 9. We have a very bright white that we print and are able to over print the BK with no wet out keeping it very legible. Is this option ? Thank you Daniels […]
- [Q&A: Is it necessary to display placards if I'm hauling 2,205 lb of just one type of HazMat (Division 2.2)?](https://danielstraining.com/qa-is-it-necessary-to-display-placards-if-im-hauling-2205-lb-of-just-one-type-of-hazmat-division-2-2/): Question1: Hello, I was hoping to get some clarification on this. I have highlighted the section in red that I am questioning. If I have less than 2,205lbs of just one type of hazard identified in table 2, non-flammable gas 2.2 to be exact, then it doesn’t need to be placarded? Or does it if it is over 1,001 lbs? It seems like the 1,001 lbs rule applies if you are combining 2 or more hazards identified in table 2? https://www.govregs.com/regulations/49/172.504 (b) DANGEROUS placard. A freight container, unit load device, transport vehicle, or rail car which contains non-bulk packages with two or […]
- [Q&A: Is a 55-gallon drum of waste gasoline also a reportable quantity (RQ) of a hazardous substance?](https://danielstraining.com/qa-is-a-55-gallon-drum-of-waste-gasoline-also-a-reportable-quantity-rq-of-a-hazardous-substance/): Question: I’d like to commend you for the great Q&A on your website. I have referred others to answers on HW and HM Qs over the years, as you always do a great job of explaining why something does/doesn’t apply. I saw your answer that there is no RQ for gasoline as an HM: Q&A: How much diesel fuel is a reportable quantity (RQ) of a hazardous substance?, but what about when it’s waste gasoline? As it carries a D001 waste code it seems like it would apply in cases where it exceeds the D001 threshold (100 lbs). Answer: Thank […]
- [FAQ: Can a damaged, defective, or recalled (DDR) lithium cell or battery be managed as universal waste?](https://danielstraining.com/faq-can-a-damaged-defective-or-recalled-ddr-lithium-cell-or-battery-be-managed-as-universal-waste/): 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 is responsible for determining whether the spent lithium batteries they generate are hazardous waste and, if they are, how they are to be managed in compliance with Federal and State hazardous waste requirements. One compliance option is to manage the hazardous waste lithium batteries as a universal waste. A handler of universal waste may only manage broken or damaged lithium […]
- [Q&A: Are orientation arrows required on a package containing pressurized gas?](https://danielstraining.com/qa-are-orientation-arrows-required-on-a-package-containing-pressurized-gas/): 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 package contains liquid hazardous materials. However, I’m wondering if any such requirements apply to pressurized gas hazardous materials? Are orientation arrows required in that case as well, or does the regulation just apply to liquids? Thank you so much for your help! Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://danielstraining.com/ Answer: Thank you for contacting me. Please see below. No. Orientation […]
- [Q&A: Commercial Driver's Licensed and HazMat Endorsement in California](https://danielstraining.com/qa-commercial-drivers-licensed-and-hazmat-endorsement-in-california/): 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 500 pounds of hazardous materials of the type requiring placards pursuant to Section 27903 , shall be licensed in accordance with this code, unless specifically exempted by this code or regulations adopted pursuant to this code.  This license shall be available for examination and shall be displayed in accordance with the regulations adopted by the commissioner.” If I am charging […]
- [Q&A: Is the Cargo Aircraft Only label required for UN3480?](https://danielstraining.com/qa-is-the-cargo-aircraft-only-label-required-for-un3480/): 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 is my understanding that this label is only for UN3090 & UN3091.. This is a charger for phones, attached is the MSDS sheet. Can you possibly let me know if we are to use the Cargo Aircraft only? Our plan is to ship via USPS, FedEx and/or UPS. Can you possibly provide some insight on this? Again question is do […]
- [Q&A: Is this a class 2 non-hazardous industrial solid waste in Texas?](https://danielstraining.com/qa-is-this-a-class-2-non-hazardous-industrial-solid-waste-in-texas/): 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. Can you provide me with your comments on the following for waste classification in Texas for Class II classification? We have a pretreatment system that we use to pre-clean metal parts prior to powder coating process and the tanks (1-6) go through a Quarterly PM (pressure washing process of all tanks internal walls and floor after first being emptied into […]
- [FAQ: When does a LQG have to update its contingency plan?](https://danielstraining.com/faq-when-does-an-lqg-have-to-update-its-contingency-plan/): 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 of your hazardous waste generator category? Take this short survey The regulations in §262.263 define five situations where a LQG must review and, if necessary, update its contingency plan: When applicable regulations are revised and require a change. Significant changes were made to these regulations by the Generator Improvements Rule. When a plan fails in an emergency. When a generator […]
- [Q&A: My HazMat packagings have been emptied and rinsed. Are they OK to ship as non-HazMat?](https://danielstraining.com/qa-my-hazmat-packagings-have-been-emptied-and-rinsed-are-they-ok-to-ship-as-non-hazmat/): 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 and ship them ? Regards, Answer (03.17.21): Thank you for contacting me. Please see below. There are two options for the transport of these packagings in compliance with the Hazardous Materials Regulations (HMR) of USDOT/PHMSA: Option 1: No Hazard The transportation of a packaging is not subject to the HMR under the following conditions: It is unused. It has been […]
- [Q&A: Is a HazMat Driver required for the transportation of UN3481 lithium ion batteries in snow blowers?](https://danielstraining.com/qa-is-a-hazmat-driver-required-for-the-transportation-of-un3481-lithium-ion-batteries-in-snow-blowers/): 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 hazmat certified driver. These batteries inside of these snowblowers weigh about 8lbs and the total weight on the full truck loads is 448lbs. What are your thoughts? Do you think we will need a hazmat driver or could we technically use a normal driver? Thanks in advance Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://danielstraining.com/ My reply 01.29.21: Thank you for […]
- [Q&A: Is the transport of government HazMat by a private company on a public road (within a college campus) subject to USDOT Regulations?](https://danielstraining.com/qa-is-the-transport-of-government-hazmat-by-a-private-company-on-a-public-road-within-a-college-campus-subject-to-usdot-regulations/): 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 be an operative word here, would you consider the transportation of hazmat by a non-government company on public roads from one university building to another “in commerce”? The materials are not being sold, but rather just moved to a new building so the old one can be renovated. I assume that since we would be giving money to the vendor […]
- [FAQ: What is a common carrier?](https://danielstraining.com/faq-what-is-a-common-carrier/): 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 does the HMR define a contract carrier or private carrier. Fortunately, I explain these terms for you in these articles: FAQ: What is a contract carrier? FAQ: What is a private carrier? Even stranger, a third type of carrier: a common carrier, is not documented in the empty packaging exception at all even though understanding its characteristics is necessary for […]
- [Q&A: Where do I indicate the use of a State authorization on the IATA DGD?](https://danielstraining.com/qa-where-do-i-indicate-the-use-of-a-state-authorization-on-the-iata-dgd/): I get questions from around the world! Like this one on February 16, 2021: Hello, Let me introduce myself, I am <<Name>> from Belgium. I’m trying to understand the DGR to help a friend who is about to take her IATA category 6 exam. I have no experience in the transportation of dangerous goods. I found your site by chance while doing a search on the Q Value. Your explanation is interesting. Read: Calculating the “Q” Value for Different Dangerous Goods in a Single Outer Packaging (All Packed in One) On the other hand, I have a question: in practice, […]
- [Q&A: Am I required to register with USDOT based on the HazMat I receive at my facility?](https://danielstraining.com/qa-am-i-required-to-register-with-usdot-based-on-the-hazmat-i-receive-at-my-facility/): A question from a previous trainee (12.09.20): Hi Daniel. I was wondering if you’d be able to answer another question for me. I took your class a few months ago, and still trying to wrap my head around all of this. We do not ship from our site any HazMat that requires registration. However, we receive 190 proof ethyl alcohol, do we need to register as a hazmat handler? My reply that same day: No. Registration is only required for persons who offer for transportation (shipper) or transport in commerce (carrier) a shipment containing any one of the categories specified […]
- [Proper use of the Cargo Aircraft Only Label](https://danielstraining.com/proper-use-of-the-cargo-aircraft-only-label/): Purpose: The purpose of this article is to explain the use, restrictions, requirements, & limitations for the display of the Cargo Aircraft Only label for the air transport of dangerous goods. Introduction: Perhaps the most unusual in appearance of all hazard communication used by the transportation regulatory agencies is the Cargo Aircraft Only label. Black letters and images on an orange background. An image of a passenger aircraft (notice the seats?) with a cartoon human figure. The human figure has an outlandishly enlarged hand preventing a pallet of dangerous goods from being loaded on the aircraft. To further convey the […]
- [Q&A: Do I display the HazMat's identification number on the limited quantity sticker?](https://danielstraining.com/qa-do-i-display-the-hazmats-identification-number-on-the-limited-quantity-sticker/): Question (11.23.21): Hi Daniel, I saw your video on YouTube and had a couple questions I was hoping you could answer for me. Regarding Limited Quantities, does the UN number get written on the Limited Quantities sticker? Answer (11.23.21): Thank you for contacting me. Please see below. No. the ID# for a HazMat is never displayed on the limited quantity mark. Nothing may be displayed on the limited quantity mark. The ID# is not displayed anywhere on a package of a limited quantity unless it is to be transported by air. The only required marks and labels on a limited quantity by […]
- [FAQ: Who must receive HazMat Employee training?](https://danielstraining.com/faq-who-must-receive-hazmat-employee-training/): Before we begin… The Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) creates and enforces the Hazardous Materials Regulations (HMR) for the transportation of hazardous materials (HazMat) to, from, or through the U.S. According to 49 CFR 171.8 of the HMR, a hazmat employer is “A person who employs or uses at least one hazmat employee on a full-time, part time, or temporary basis.” According to §171.8, a hazmat employee is any employee who is “Employed on a full-time, part time, or temporary basis by a hazmat employer and who in the course of such […]
- [Q&A: Must I display the HazMat's identification number on my vehicle when transporting (essentially empty) IBCs?](https://danielstraining.com/qa-must-i-display-the-hazmats-identification-number-on-my-vehicle-when-transporting-essentially-empty-ibcs/): A question 11.22.21: Hello I have been asked to transport IBC containers containing trace (essentially empty) amounts of several types with id #1789/1790/1835/2031 am I correct in assuming they should still be identified by their numbers on the outside of my trailer even though they are in small quantities? I am in New York… 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 Info@DanielsTraining.com https://danielstraining.com/ My answer: You are correct. A bulk packaging (e.g., IBC or intermediate bulk container) that contains […]
- [FAQ: What's "in commerce" mean?](https://danielstraining.com/faq-whats-in-commerce-mean/): Scope and Applicability: The transportation in commerce of hazardous materials (HazMat) within the U.S. 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). What is meant in the Hazardous Materials Regulations of USDOT/PHMSA by “in commerce” when establishing the applicability of the HMR? Let’s begin at the beginning. The very first sentence of the HMR at 49 CFR 171.1 reads, “Federal hazardous materials transportation law (49 U.S.C. 5101 et seq.) directs the Secretary of Transportation to establish regulations for the safe and secure transportation of hazardous […]
- [Q&A: I'm a homeowner shipping HazMat. Am I subject to USDOT regulations?](https://danielstraining.com/qa-im-a-homeowner-shipping-hazmat-am-i-subject-to-usdot-regulations/): Question received 11.22.21: Hi Daniel, Wondering if you have time to help with a quick question. I am an individual homeowner, not contractor or company. I would like to ship 24 quart cans of leftover paint by ground transport from my City, Arizona home to my City, California home. I found out that this seems to be UN1263 and falls under packing group II or III. It is not clear if I can claim a small quantity or limited quantity or or ORM-D exclusion, so I am just planning to mail it using UN Specification Packaging: https://bascousa.com//hazmat-packaging-with-foam-and-quart-paint-cans-4g-4q.html I was hoping […]
- [Q&A: Am I required to display the HazMat's identification number on the vehicle if its displayed on an IBC in the same manner as a non-bulk packaging?](https://danielstraining.com/qa-am-i-required-to-display-the-hazmats-identification-number-on-the-vehicle-if-its-displayed-on-an-ibc-in-the-same-manner-as-a-non-bulk-packaging/): Before we begin… IBC is an intermediate bulk container. Hazard communication on an IBC can be complex and includes several options. One option is to display the hazard communication (labels and marks) on the IBC in the same manner as on a non-bulk packaging. Read: HazMat Labels, Markings, and Placards on an Intermediate Bulk Container The USDOT/PHMSA Hazardous Materials Regulations identify three situations when a HazMat’s identification number must be displayed on a transport vehicle. The transport vehicle itself is a bulk packaging (e.g., cargo tank, rail tank car). The transport vehicle contains a bulk packaging (e.g., IBC) and the […]
- [Q&A: Can employees use personal vehicles to transport Division 6.2, Category B samples as Materials of Trade?](https://danielstraining.com/qa-can-employees-use-personal-vehicles-to-transport-division-6-2-category-b-samples-as-materials-of-trade/): Question: Hi Daniel, Thank you for your help. I have another issue, I’d like to run by you. I have been allowing trained researcher to use their personal vehicles for single use transportation of exempt samples, patient samples that could be Cat B (NOT Cat B cultures) and unregulated biological samples under MOTS (aka: the Materials of Trade exception). As I interpret the DOT MOTS, that is allowed. Would you agree with this assessment? Thanks again, My reply: Yes. that is OK under the Materials of Trade exception as long as you comply specifically with 49 CFR 173.6(a)(4) and the […]
- [Q&A: What are the IATA training certification requirements?](https://danielstraining.com/qa-iata-certification-requirements/): Before we begin… This Q&A is based on the 63rd Edition of the IATA Dangerous Goods Regulations, effective in calendar year 2022. Sent from the Contact Me page of my website: Message Body: I have an on-line shipping training on the IATA Dangerous Goods Regulations for researchers at my institution on shipping biologicals and dry ice by air. A test is given and upon passing they get a certificate with my name and the date on it along with a description of the course: Shipping Dangerous Goods training and Class 6.2 Infectious substances and Class 9 Miscellaneous Goods. Our parent […]
- [Revised Packing Instructions for Lithium Cells and Batteries - Effective 03.31.22](https://danielstraining.com/revised-packing-instructions-for-lithium-cells-and-batteries-effective-03-31-22/): Introduction: The 63rd Edition of the IATA Dangerous Goods Regulations (effective January 1 through December 31, 2022) includes significant changes to the packing instructions for lithium cells and batteries when packed alone (UN3480 for lithium ion or UN3090 for lithium metal). The purpose of this article is to explain the removal of Section II from packing instructions 965 and 968 from the 2022 IATA Dangerous Goods Regulations for lithium cells and batteries. Background: IATA is the International Air Transport Association. It is a trade association of the world’s airlines. It supports aviation with global standards for airline safety, security, efficiency […]
- [Q&A: Is HazMat Employee training required to sign the uniform hazardous waste manifest when used for PCB waste?](https://danielstraining.com/qa-is-hazmat-employee-training-required-to-sign-the-uniform-hazardous-waste-manifest-when-used-for-pcb-waste/): Before we begin… The content of this Q&A is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). PCBs – or Polychlorinated biphenyls – are a highly toxic product whose production was banned by United States federal law in 1978, and by the Stockholm Convention on Persistent Organic Pollutants in 2001. It is an organic chlorine compound. RCRA is the Resource Conservation and Recovery Act. It is the primary source of law upon which the Federal hazardous waste regulations of the U.S. Environmental Protection Agency (USEPA) are […]
- [Transport of Aerosols in Metal Containers by Highway, Rail, or Vessel Within the U.S.](https://danielstraining.com/transport-of-aerosols-in-metal-containers/): Introduction: Aerosols are a common product found in almost every residential and commercial setting. They are also – usually – a hazardous material (HazMat) subject to the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) when transported or offered for transport within the U.S. However, an exception from most of the HMR is available to aerosols – and other compressed gasses – at 49 CFR 173.306. The purpose of this article is to identify and explain the limited quantity exception for aerosols in metal containers at 49 CFR 173.306(i). […]
- [General Pressure Conditions for Metal Aerosol Containers at 49 CFR 173.306(a)(ii)](https://danielstraining.com/general-pressure-conditions-for-metal-aerosol-containers-at-49-cfr-173-306aii/): Introduction: In a separate article I describe the requirements of 49 CFR 173.306 for Limited quantities of compressed gases as they apply to aerosol. A portion of those regulations indicates authorized metal aerosol containers and associated pressure limitations. In order to simplify my separate article on shipping aerosols as a limited quantity, I will detail the general pressure conditions of §173.306(a)(3)(ii) in this article. Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Before we begin… §173.306(a) is just the beginning of the limited quantity exception […]
- [Q&A: Does my truck transporting a "modular power unit" with lithium batteries require the display of placards?](https://danielstraining.com/qa-does-my-truck-transporting-a-modular-power-unit-with-lithium-batteries-require-the-display-of-placards/): Before we begin… All of the following is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). Question (10.20.20): You seem to have the most info and the most accurate info regarding highway transportation of hazmat. Recently I hauled this “modular power unit” from NM to NY. At the delivery point the job super asked why it wasn’t placarded, I told him I wasn’t tendered the load as hazmat, so I had no idea. He told me the unit was a battery backup for GE and contained […]
- [Q&A: Can I reuse plastic HazMat packagings for off-site transport of hazardous waste?](https://danielstraining.com/qa-can-i-reuse-plastic-hazmat-packagings-for-off-site-transport-of-hazardous-waste/): Question (January 09, 2021): Good morning, We are reusing plastic drums to send waste back out. The max net mass is 400 kg. Does that mean we cannot fill the drums over 400 kg each drum, even if palletized for transport? Thank you, Answer (January 18, 2021): Thank you for contacting me. I apologize for my delay. There are several issues brought up by your question that I will address in addition to answering your question. Please see below. Note: all of the following is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration […]
- [Q&A: What are the requirements for the IATA training certificate?](https://danielstraining.com/qa-what-are-the-requirements-for-the-iata-training-certificate/): Before we begin… The Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) creates and enforces the Hazardous Materials Regulations (HMR) for the transportation of hazardous materials (HazMat) to, from, or through the U.S. The Dangerous Goods Regulations of the International Air Transport Association (IATA) are produced in consultation with the International Civil Aviation Organization (ICAO) and are the guide recognized by the world’s commercial airlines for the transportation of dangerous goods by air. The content of this Q&A is based on the 63rd Edition of the IATA Dangerous Goods Regulations, effective January 01, 2022 until […]
- [Q&A: Will an industry "rule of thumb" work for filling HazMat packagings for transportation?](https://danielstraining.com/qa-will-an-industry-rule-of-thumb-work-for-filling-hazmat-packagings-for-transportation/): Question: Subject: Container head space for UN rated drums containing liquids Message Body: Are there any regulations in reference to how much liquid can be added to a drum? e.g. 1A1 – 55 gal drum. When dealing with drums containing flammable liquids during summer months to ensure adequate container head space for vapor expansion. Most in the industry have a “rule of thumb”… Answer: Thank you for contacting me. There are several regulatory requirements applicable to the filling of packagings with a hazardous material (HazMat) prior to offering it for transportation. Please see below for some initial clarification: My answers […]
- [Q&A: If our shipments never require placards do we need to have placards available?](https://danielstraining.com/qa-if-our-shipments-never-require-placards-do-we-need-to-have-placards-available/): Question: If our shipments never require placards do we need to have placards available? Answer: That’s a good question. Please see below. The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety administration within the U.S. Department of Transportation (USDOT/PHMSA) require the shipper to provide placards to the driver unless the motor vehicle already displays the required placards. [49 CFR 172.506(a)] A shipper that offers hazardous materials (HazMat) for transportation in quantities that require the display of placards on the vehicle should therefore have a supply of the applicable placards in order to be able to provide them […]
- [Q&A: How much diesel fuel is a reportable quantity (RQ) of a hazardous substance?](https://danielstraining.com/qa-how-much-diesel-fuel-is-a-reportable-quantity-rq-of-a-hazardous-substance/): Question: Daniel: I just had a question asked to me about reportable quantities. They asked what the reportable quantity for diesel fuel was as well as gasoline. So I went to the Hazardous Materials Compliance Pocketbook to Table 1 but could not find anything around fuel. They claim its 10 gallons, I looked it up and it was 25gal. according to the internet but that does not help me as far as the HAZMAT/Safety guy around here and you always seem to know that type of stuff. Can you give me an explanation of why it is not in there? […]
- [Q&A: Can I ship r12 refrigerant by air as a Consumer Commodity? Can I use the U.S. Postal Service?](https://danielstraining.com/qa-can-i-ship-r12-refrigerant-by-air-as-a-consumer-commodity-can-i-use-the-u-s-postal-service/): SUBJECT LINE: Consumer Commodity how did this change in 2021 DATE: Feb 7, 2021, 2:39 PM Question: Authorization for use of ORM-D Classification (Consumer Commodity) I ship small quantity packages of r12 refrigerant by air starting in about a month it is still a consumer commodity. Is it still exempted from all the placards and and paper work. How do I need to mark it. Consumer Commodity and the UN1028? Can you explain what I need I would appreciate it. My reply the next day: Thank you for contacting me. I will try to answer your questions below. The consumer […]
- [Q&A: Is my plastic packaging OK for HazMat transport after five years?](https://danielstraining.com/qa-is-my-plastic-packaging-ok-for-hazmat-transport-after-five-years/): A question 02.23.21: Good morning, I am the supervisor of the transportation of my organization. We are a small operation and have 2 plastic 5 gallon pails (1H2), that we utilize only for ground transport on our own vehicle (own driver) to move small quantities of samples from our lab to another off-site lab (about 3 miles away). We use these very infrequently if sample size exceeds excepted quantity amounts. The pails were manufactured in 2011 and I have the UN Certification testing documentation and closure instructions. My question is whether this packaging is now considered expired? And if not […]
- [FAQ: What - or who - is a person (according to USEPA)?](https://danielstraining.com/faq-what-or-who-is-a-person-according-to-usepa/): The Federal regulations of the U.S. Environmental Protection Agency (USEPA) and those of your state, if it has an authorized hazardous waste program, frequently use the word “person”. e.g., “a generator is any person…”, or “Persons who own or operate facilities…” It is therefore important to understand how USEPA defines the word person when used in its hazardous waste regulations.
- [FAQ: What - or who - is a person (according to the USDOT/PHMSA)?](https://danielstraining.com/faq-what-or-who-is-a-person-according-to-the-usdot-phmsa/): In its Hazardous Materials Regulations (HMR), the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) frequently uses the word “person”. e.g., “person who offers or offeror” or “each person who imports…” But don’t think how you understand the word is how USDOT/PHMSA defines and regulates it.
- [Importing Hazardous Materials Into the U.S.](https://danielstraining.com/importing-hazardous-materials-into-the-u-s/): The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) apply to all transport of hazardous materials (HazMat) to, from, or through the U.S. The import of HazMat into the U.S. requires compliance with international regulations during the period it is not within U.S. territory. The HMR at 49 CFR 171.22 authorizes the use of international standards and regulations for the transportation of HazMat (known as dangerous goods in the international regulations) in the U.S. with certain conditions. §171.22(f) specifies the information and certification required for a HazMat to be […]
- [Q&A: Is secondary containment required for used oil?](https://danielstraining.com/qa-is-secondary-containment-required-for-used-oil/): A question 09.28.20: Hi Daniel, I have inquired with you in the past and I am hoping you would be willing to help me again. I have 55 gallon oil drums (used oil) in a few locations around my facility. I am having a hard time finding if these containers need to be on secondary containment or not. What is your input? Thanks, My reply that same day: Please see below. The regulations of the U.S. Environmental Protection Agency (USEPA) for the management of used oil are found in 40 CFR 279. In sum, the USEPA regulations allow for the […]
- [Q&A: What USDOT regulations apply to large containers of alcohol wipes?](https://danielstraining.com/qa-what-usdot-regulations-apply-to-large-containers-of-alcohol-wipes/): A question November 17, 2020: Hi Daniel, I came across your site via this page: The Classification of Alcohol Wipes Very interesting, and complex stuff, I really thought your analysis was great and very informative. Can I ask you, how would you classify large-format buckets of alcohol wipes? I am starting a new venture to export buckets of 1000 alcohol wipes to the USA and I would be interested to have your opinion on this – in each bucket we are putting about 1500 mL of solution in to saturate the wipes, which are then heat-sealed in a bag, and […]
- [FAQ: Can the signor of the uniform hazardous waste manifest be held personally liable?](https://danielstraining.com/faq-can-the-signor-of-the-uniform-hazardous-waste-manifest-be-held-personally-liable/): Yes. I’ll just let that sink in… Usually it will be the company represented by the signor, i.e., the generator or offeror of the hazardous waste that is subject to enforcement actions. However, in situations of egregious or criminal violations, the signor could be held personally liable. Read question #3 of RO 14687 Like this article? Subscribe to my Monthly Newsletter No marketing emails!
- [Q&A: When does my hazardous waste generator category change?](https://danielstraining.com/qa-when-does-my-hazardous-waste-generator-category-change/): Question December 03, 2020: Hi Daniel, Hope you are doing well and enjoying the season so far 😊 I was hoping you could help me with another regulatory question regarding counting waste – or point me in the right direction. My question is about weekly inspections when a site becomes a SQG (200-2,200 lbs./mo.). Here’s the scenario: A generator became a SQG in October when hazardous waste was generated in that month and weekly inspections have been conducted since that time while the waste has been on site. The weekly inspections will be stopped once the hazardous waste is shipped […]
- [Quick Take: USDOT/PHMSA Releases DOT Chart 17 July 08, 2021. Replaces DOT Chart 16.](https://danielstraining.com/quick-take-usdot-phmsa-releases-dot-chart-17-july-08-2021/): USDOT/PHMSA (the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation) released the DOT Chart 17 – Hazardous Materials Markings, Labeling and Placarding Guide on July 08, 2021. It replaces the DOT Chart 16 issued in August of 2017. The purpose of the DOT Chart 17 is to assist shippers, carriers, and other stakeholders to quickly access information regarding hazardous materials markings, labels and placards. Changes from the DOT Chart 16 to DOT Chart 17 are: A new color scheme. Hazardous Materials Markings: Identification number display per 49 CFR 172.332 now includes the option of the white […]
- [Quick Take: USDOT/PHMSA Revision to Class 9 Miscellaneous Label](https://danielstraining.com/quick-take-usdot-phmsa-revision-to-class-9-miscellaneous-label/): The Bullet: Effective January 20, 2021 there are no longer two options for display of the Class 9 Miscellaneous label. As of o1.20.21, the only acceptable Class 9 label design is that without the horizontal line running across the label at its midpoint. More information: This change is to the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). The final rule was published in the Federal Register at 85 FR 83381, Dec. 21, 2020. In a final rule published July 20, 2011, HM-218F [76 FR 43510], USDOT/PHMSA revised the […]
- [Q&A: Can I combine two or more HazMat in the same packaging?](https://danielstraining.com/qa-can-i-combine-two-or-more-hazmat-in-the-same-packaging/): Question – September 27, 2020 Subject: Mixed hazmat in same packaging What are the rules for shipping compatible hazardous materials having different hazard classes packed within the same packaging? What are the quantity limits per package? I do not find a regulatory reference in 49 CFR for shipping mixed hazmat in the same package. Does such a rule exist? Thanks! Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://danielstraining.com/ My reply (10.06.20): Thank you for contacting me. I apologize for my delay. Please see below. This reply is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety […]
- [Q&A: Who is responsible for removing the placards from a freight container once transport of HazMat is complete?](https://danielstraining.com/qa-who-is-responsible-for-removing-the-placards-from-a-freight-container-once-transport-of-hazmat-is-complete/): It all began with a telephone call on November 18, 2020: We receive hazardous materials delivered to our facility in a freight container. The freight container displays the required placards. The carrier deposits the freight container at our facility and departs. We unload the HazMat from the freight container over the next few hours. When making the next delivery the carrier retrieves the now empty freight container and take it I know not where. It is been an ongoing argument with the carrier as to who is responsible for removing the placards from the empty freight container. They are displayed […]
- [FAQ: What articles or substances do not require a "Shipper's Declaration for Dangerous Goods"?](https://danielstraining.com/faq-what-articles-or-substances-do-not-require-a-shippers-declaration-for-dangerous-goods/): Per Section 8 – Documentation of the International Air Transport Association (IATA) Dangerous Goods Regulations, a “Shipper’s Declaration for Dangerous Goods” must be completed by the shipper of each consignment of dangerous goods, except for the following: UN3164, Articles, pressurized, hydraulic (see Packing Instruction 208(a)). UN3164, Articles, pressurized, pneumatic (see Packing Instruction 208(a)). UN3373, Biological substance, Category B (see Packing Instruction 650). UN1845, Carbon dioxide, solid (Dry ice) when used as a refrigerant for other than dangerous goods (see Packing Instruction 954(c)). Dangerous goods in excepted quantities (see 2.6.8). UN3245, Genetically modified organisms, Genetically modified microorganisms (see Packing Instruction 959). […]
- [Q&A: Are my alcohol wipes subject to USDOT Regulations?](https://danielstraining.com/qa-are-my-alcohol-wipes-subject-to-usdot-regulations/): A question asked on December 09, 2020: Hello, I found your article The Classification of Alcohol Wipes, and was hoping you could clarify for me: We currently have these classified as a class 4.1 packing class II. We have been requiring our driver to placard when this item is over 1000 lbs. I think I am reading your article correctly, that since these are in sealed packages, AND there is no free liquid, it is not regulated by the DOT. Is that correct? If so, there may be very little free liquid in the package, would that change it? One […]
- [FAQ: Is online training allowed for facility personnel of a large quantity generator of hazardous waste?](https://danielstraining.com/faq-is-online-training-allowed-for-facility-personnel-of-a-large-quantity-generator-of-hazardous-waste/): Answer: Yes. The Generator Improvements Rule made a technical change to the regulations for personnel training at a large quantity generator of hazardous waste (LQG). This change to 40 CFR 262.17(a)(7)(i)(A) was made by the U.S. Environmental Protection Agency (USEPA) to bring the hazardous waste personnel training regulations up to date with existing industry practices. Therefore, USEPA revised the regulations to allow a LQG to use online computer training in addition to classroom instruction and on-the-job training. The regulations include examples of online training: computer-based or electronic. Contact me with any questions you may have about the generation, identification, management, […]
- [Personnel Training for Hazardous Waste Generator](https://danielstraining.com/personnel-training-for-hazardous-waste-generator/): The employees (aka: personnel) of a large quantity generator of hazardous waste (LQG) must successfully complete initial training with an annual review. Regulations of the U.S. Environmental Protection Agency (USEPA) mandate such training be provided in order for the LQG to maintain its exemption from regulation as a treatment, storage, or disposal facility (TSDF) of hazardous waste. The purpose of this article is to explain the Federal regulations of the USEPA at 40 CFR 262.17(a)(7) for training of personnel at a large quantity generator of hazardous waste.
- [Q&A: Is an emergency response telephone number required?](https://danielstraining.com/qa-is-an-emergency-response-telephone-number-required/): A question received October 16, 2020: Hello, my name is <<Name>> at <<Company>> in <<City, State>> a freight forwarder. I found an article regarding CANUTEC you wrote, and I am writing this email because I need your help. We have several hazmat import containers that containing butane steel cartridges, and SM Line, ocean carrier requested “24hrs emergency contact” on the IMO/Multimodal DG Form in one of the four companies below for inland rail transportation. Chemtrec, Infortace, Chemtel, Canutec We have handled the exact same cargo for 3~4years with other carriers, but never had like this problem. I don’t know what […]
- [Q&A: How do I mail a product containing a lithium metal button cell battery?](https://danielstraining.com/qa-how-do-i-mail-a-product-containing-a-lithium-metal-button-cell-battery/): A question received September 23, 2020: Hi Daniel, I just stumbled across your website and specifically this article: March 6, 2019: USDOT Changes Regulations for Transport of Lithium Batteries I am trying to mail a water filter like the one in the image I attached. When it showed up to me it had some of the UN stickers and said “forbidden for transport by air or vessel”. It does have some type of battery in it to monitor when the filter life is up. My question is, do I need to provide one of the UN stickers on the attached […]
- [Examples of the Meaning of "Under the Control of the Operator"](https://danielstraining.com/examples-of-the-meaning-of-under-the-control-of-the-operator/): The previous regulations for accumulation of hazardous waste in a satellite accumulation area (SAA) and those revised by the Generator Improvements Rule, do not define the term, “under the control of the operator”. In an effort to assist generators to better understand this term and to foster improved compliance with the SAA regulations, USEPA provided examples in the preamble to the proposed rule and requested comments on additional practices that would constitute “under he control of the operator.” These examples were provided in the preamble to the final rule. The purpose of this article is to provide examples of “under […]
- [FAQ: Must the "Operator" of a satellite accumulation area be a single individual?](https://danielstraining.com/faq-must-the-operator-of-a-satellite-accumulation-area-be-a-single-individual/): Background: The satellite accumulation area (SAA) regulations of the US. Environmental Protection Agency (USEPA) at 40 CFR 262.15 mandate that the container of hazardous waste in the SAA be “under the control of the operator of the process generating the waste,…” Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://danielstraining.com/ Answer: (FR 81, no. 228, 11.28.16 85768) USEPA believes that there can be more than one operator per SAA over time. For example, as employees change shifts over the course of a day, the role of the operator can be transferred from one employee to another. Likewise, the Agency believes that there […]
- [USEPA Rescinds Memo Regarding Accumulating Reactive Hazardous Waste Away From the Point of Generation](https://danielstraining.com/usepa-rescinds-memo-regarding-accumulating-reactive-hazardous-waste-away-from-the-point-of-generation/): USEPA’s RCRA Online is a source for memos and guidance from USEPA regarding the hazardous waste regulations. In a memo dated January 13, 1988, USEPA wrote that a storage shed located outside of a building where a reactive hazardous waste (D003) is initially generated could be considered a SAA (RO 11317). The Generator Improvements Rule rescinded this memo and revoked this interpretation. The purpose of this article is to explain the USEPA changing its interpretation of “at or near the point of generation” by rescinding an earlier interpretation.
- [Generator May Choose to Manage Hazardous Waste in a Satellite Accumulation Area](https://danielstraining.com/generator-may-choose-to-manage-hazardous-waste-in-a-satellite-accumulation-area/): The satellite accumulation area (SAA) regulations provide an option for generators to manage hazardous waste containers instead of in a central accumulation area (CAA). Containers managed in a SAA are not required to comply with many of the regulations applicable to the large quantity generator (LQG) and small quantity generator (SQG). Revisions to these regulations by the Generator Improvements Rule now clarify the option to manage hazardous waste in a SAA and the relief from regulation it provides. The purpose of this article is to explain the rewording of 40 CFR 262.15(a) clarifying the generator option to manage hazardous waste […]
- [Responding to Leaking or Damaged Containers in the Satellite Accumulation Area](https://danielstraining.com/responding-to-leaking-or-damaged-containers-in-the-satellite-accumulation-area/): Based on a recommendation from commenters, USEPA made a minor wording change to 40 CFR 262.15(a)(1) to explicitly require an immediate response to a leaking or damaged container in a satellite accumulation area (SAA). The revised regulations also clarify the applicable regulations if the container is moved to a central accumulation area (CAA). This change is part of the many revisions to generator regulations made by the Generator Improvements Rule. The purpose of this article is to explain the addition of the word “immediately” and other language to 40 CFR 262.15(a)(1) regarding containers that are not in good condition or […]
- [Applicability of Preparedness, Prevention, & Emergency Procedures to Satellite Accumulation Area](https://danielstraining.com/applicability-of-preparedness-prevention-and-emergency-procedures-to-satellite-accumulation-area/): Prior to the Generator Improvements Rule, the waste accumulated in a SAA was not subject to the preparedness, prevention, and emergency procedure regulations; but that’s changed. Under the revised regulations all areas of a facility where hazardous waste is generated, accumulated, or treated is subject to the regulations of §262, Subpart M or §262.16(b)(8-9). That, of course, includes hazardous waste in a SAA. The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(7-8) that expand the applicability of the preparedness, prevention and emergency procedure regulations to the satellite accumulation area.
- [USEPA Modifies the Language for Generator Options When the Maximum Volume or Weight is Exceeded in a Satellite Accumulation Area](https://danielstraining.com/modifying-language-when-maximum-volume-or-weight-is-exceeded-in-saa/): Generators that accumulate waste in a satellite accumulation area (SAA) must comply with the regulations of 40 CFR 262.15. This includes maintaining waste below certain volume and/or weight thresholds and then complying with specific requirements when those thresholds are exceeded. Prior to the Generator Improvements Rule the regulations specifying generator requirements after the threshold weight or volume was exceeded in a SAA were not clear; the revised regulations change this. The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(6) that more clearly state the generator options for managing “excess waste” in a satellite accumulation area.
- [USEPA Provides a Maximum Weight for Acute Hazardous Waste Accumulation in a Satellite Accumulation Area](https://danielstraining.com/maximum-weight-acute-hazardous-waste-in-satellite-accumulation-area/): Generators of hazardous waste may accumulate acute hazardous waste and/or non-acute hazardous waste in containers in a satellite accumulation area (SAA). Prior to the Generator Improvements Rule USEPA used separate volume thresholds for these two wastes: one quart or fifty-five gallons, respectively. When the volume threshold is exceeded, the generator must take certain actions within a certain time-frame to continue in compliance with the SAA regulations of 40 CFR 262.15. Revisions of the Generator Improvements Rule added a weight threshold for acute hazardous waste accumulated in a SAA. The purpose of this article is to explain the regulations at 40 […]
- [USEPA Clarifies "three days" for Removal of Hazardous Waste From Satellite Accumulation Area to Central Accumulation Area](https://danielstraining.com/three-consecutive-days-in-satellite-accumulation-area/): Generators who accumulate hazardous waste in a satellite accumulation area (SAA) are likely familiar with the requirement to remove waste from the SAA to the central accumulation area (CAA) when the threshold volume is reached. A generator may also be aware this must be done within three (3) days. The previous SAA regulations at 40 CFR 262.34(c)(2) vaguely indicated this removal be accomplished, “within three days”. Under the Generator Improvements Rule, the USEPA amended the regulations to replace the term “three days” with “three consecutive calendar days”. The purpose of this article is to explain the regulations at 40 CFR […]
- [Q&A: How do I transport empty DOT 406 bulk fuel cargo tanks from Europe to U.S.?](https://danielstraining.com/qa-how-do-i-transport-empty-dot-406-bulk-fuel-cargo-tanks-from-europe-to-u-s/): A question from a soldier in the U.S. Army on July 20, 202o: CLASSIFICATION: UNCLASSIFIED Hello Daniels Training Services, INC. Team, I read through your internet article USDOT Requirements for Shipments of Empty Packagings. Thanks for posting it. I have a couple of questions on behalf of the US Army Europe. Situation: We have DOT 406 Bulk Fuel Cargo Tanks that must be returned to numerous Army bases across the USA from Europe. The tanks have contained fuel and have been completely drained (including pipes, pumps and removal filtering systems) according to the manufacturers technical manuals. There may be “Crevice” […]
- [Q&A: Must I renew the DOT specification (UN Standard) on packagings I have in stock?](https://danielstraining.com/qa-must-i-renew-the-dot-specification-un-standard-on-packagings-i-have-in-stock/): A question from a recurring customer on 09.04.20: We received the below note from our packaging supplier in regard to testing. We supply a hazardous material for transportation and ship using these boxes. Has there been any changes that you know off that would help us decide if the testing is necessary? MESSAGE FROM PACKAGING SUPPLIER: Good morning and hope all is well. The UN Certification on your 6 X 32 OZ UN SHIPPER is set to expire in November. If you plan to renew this UN certification, please ship the below test components to <<city, state>> to my ATTN […]
- [Q&A: May I transport an empty cargo tank when I don't have the HazMat endorsement on my CDL?](https://danielstraining.com/qa-may-i-transport-an-empty-cargo-tank-when-i-dont-have-the-hazmat-endorsement-on-my-cdl/): A question, September 16, 2020: Subject: placards Message Body: Sir:    If i pick up a propane truck (26,000 lb) with a new tank on it from the factory and it has the sticky placards on it can i cover them up to transport the truck to the destination?   I have a tank endorsement but no hazmat.  thank you. My reply that same day: As long as the cargo tank does not contain any HazMat at all. Not even the residue of the HazMat. Not even vapors. If you open the cargo tank and smell nothing but that fresh factory […]
- [Last Day to Submit Paper Uniform Hazardous Waste Manifests is June 30, 2021](https://danielstraining.com/last-day-to-submit-paper-uniform-hazardous-waste-manifests-is-june-30-2021/): On and after July 1, 2021, the United States Environmental Protection Agency (EPA), will no longer accept paper uniform hazardous waste manifests by mail. All hazardous waste manifests must be submitted to the EPA electronically using the e-Manifest system. Paper manifests and any continuation sheets mailed to the EPA after June 30, 2021, will be returned to the sender. To meet the Federal requirements for submitting  manifests, treatment, storage, and disposal facilities can submit paper manifests from hazardous waste generators by: Uploading an image of the paper manifest (image upload) or Uploading a data file plus image copy of the […]
- [Q&A: What labels & marks are required for a lithium metal button cell battery contained in equipment?](https://danielstraining.com/qa-what-labels-marks-are-required-for-a-lithium-metal-button-cell-battery-contained-in-equipment/): A question from someone unknown to me on September 23, 2020: Hi Daniel, I just stumbled across your website and specifically this article: https://danielstraining.com/march-6-2019-usdot-changes-regulations-for-transport-of-lithium-batteries/ I am trying to mail a water filter like the one in the image I attached. When it showed up to me it had some of the UN stickers and said “forbidden for transport by air or vessel”. It does have some type of battery in it to monitor when the filter life is up. My question is, do I need to provide one of the UN stickers on the attached image to mail it with […]
- [IATA Classification of Substances with Multiple Hazards](https://danielstraining.com/iata-classification-of-substances-with-multiple-hazards/): The Dangerous Goods Regulations of the International Air Transport Association (IATA) is the guide recognized by the world’s airlines to ensure compliance with the Technical Instructions of the International Civil Aviation Organization (ICAO). The transportation of dangerous goods (aka: hazardous materials or HazMat) by air must done in compliance with the ICAO Technical Instructions. Compliance with the IATA Dangerous Goods Regulations is one way to ensure compliance with the ICAO Technical Instructions. At 49 CFR 171, subpart C the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) authorizes compliance […]
- [Closed Containers in the Satellite Accumulation Area](https://danielstraining.com/closed-containers-in-the-satellite-accumulation-area/): Prior to the Generator Improvements Rule the regulations for generators accumulating hazardous waste in a satellite accumulation area (SAA) required containers accumulating hazardous waste to be kept closed except when necessary to add or remove waste. Under the new rule, hazardous waste containers in a SAA may remain open under limited circumstances. The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(4) that allow for limited exceptions to the closed container requirements in a satellite accumulation area.
- [Special Requirements for Incompatible Wastes and Materials in Satellite Accumulation Area](https://danielstraining.com/special-requirements-for-incompatible-wastes-and-materials-in-satellite-accumulation-area/): When first developing the satellite accumulation area (SAA) regulations in 1984 (hello Knight Rider!) the U.S. Environmental Protection agency (USEPA) inadvertently failed to account for the small quantity generators (SQG) and large quantity generators (LQG) of hazardous waste that might accumulate incompatible waste in a SAA. In the Generator Improvements Rule it fixed this oversight. The purpose of this article is to explain the regulations of 40 CFR 262.14(a)(3) – created by the Generator Improvements Rule – that now require SQGs and LQGs to comply with special requirements for incompatible wastes accumulated in a satellite accumulation area.
- [Q&A: Does a bulk packaging require the display of the HazMat's identification number on the vehicle?](https://danielstraining.com/qa-does-a-bulk-packaging-require-the-display-of-the-hazmats-identification-number-on-the-vehicle/): A question from a shipper or carrier of HazMat (07.31.20): I am hauling NA 1993 combustible liquid pg3 (2-methyoxymethylethoxy propanol) in a tote of 350 gallons. Its total weight is 2329lbs. This is the only hazmat on the truck. *bulk haz. Mat placard accordingly* Do I need to put UN number on the truck? Could you help me when is to put un number onto placards? Your help would really be appreciated. Thanks If you like this article, please share it using any of the social media platforms identified at the bottom of this article. My reply that same day: […]
- [Q&A: Will "Proprietary Ingredient 1" suffice as a technical name in the shipping description?](https://danielstraining.com/qa-will-proprietary-ingredient-1-suffice-as-a-technical-name-in-the-shipping-description/): A question from a former customer June 18, 2020: It’s been awhile, but I asked you a few questions in the past when I was working at <<Company>>. New job, new adventures. I know I have come across this before, and I can’t remember the answer. The following was copied into the email: I have run into something I have never come across before so I am tapping you both to see if I can get some assistance. We have a new item that one of our facilities is going to bring on-site that I am setting up in our […]
- [Marking and Labeling of Hazardous Waste Accumulation Units Under the Generator Improvements Rule](https://danielstraining.com/how-to-mark-and-label-hazardous-waste-for-the-generator-improvements-rule/): The Generator Improvements Rule (effective 05.30.17 in the regulations of the U.S. Environmental Protection Agency and states without an authorized hazardous waste program) will make many changes to the regulations applicable to a generator of hazardous waste. Read here for more information: Summary of the Generator Improvements Rule States and Authorized Hazardous Waste Programs USEPA Fact Sheet About the Hazardous Waste Generator Improvements Final Rule The purpose of this article is to identify and explain the USEPA regulations created by the Generator Improvements Rule that require additional hazard communication on various hazardous waste accumulation units throughout the cradle-to-grave management of […]
- ["An Indication of the Hazards of the Contents": Mark and Label Hazardous Waste Containers in a Satellite Accumulation Area Under the Generator Improvements Rule](https://danielstraining.com/indicate-the-hazards-container-in-satellite-accumulation-area-generator-improvements-rule/): Both the large quantity generator (LQG) and small quantity generator (SQG) of hazardous waste are required by Federal regulations of the United States Environmental Protection Agency (USEPA) to display hazard communication in the form of marks and labels on the hazardous waste accumulation units in use at their facility. This includes containers of hazardous waste in both the central accumulation area (CAA) and satellite accumulation area (SAA). These – and other – Federal regulations changed with the effective date of the  Generator Improvements Rule on May 30, 2017. Regulations now require the generator to indicate the hazards of the contents […]
- [Satellite Accumulation of Hazardous Waste Under the Generator of Improvements Rule](https://danielstraining.com/satellite-accumulation-of-hazardous-waste-under-the-generator-of-improvements-rule/): The option to manage hazardous waste in a satellite accumulation area (SAA) in addition to or instead of a central accumulation area (CAA) is available to both the large quantity generator of hazardous waste (LQG) and small quantity generator of hazardous waste (SQG). When accumulated in a SAA hazardous waste containers are subject to less regulation than when accumulated in a CAA. Not sure of your hazardous waste generator category? Take this short survey The Generator Improvements Rule made some changes to the regulations for the accumulation of hazardous waste in a satellite accumulation area. Moved them from their former […]
- [Q&A: Can I cure, process, then dispose universal waste paint in the garbage? Asking for a friend in Texas.](https://danielstraining.com/qa-can-i-cure-process-then-dispose-universal-waste-paint-in-the-garbage-asking-for-a-friend-in-texas/): A question from the Lone Star State August 12, 2020: Hi Daniel, I have a question pertaining to the PPRW. We are SQH and I have been trying to figure out if it’s ok to Cure, process, and then dispose of our paint that is classified as UW in the garbage. Some people are saying yes that this is allowed but I can not seem to find where the information and code for this is. I would greatly appreciate your help and advice. Note: PPRW = Universal Waste Paint and Paint-Related Waste Note: SQH = Small Quantity Handler of universal […]
- [Q&A: What are the restrictions for transporting ethanol (>70%) from Europe to West Africa?](https://danielstraining.com/qa-what-are-the-restrictions-for-transporting-ethanol-70-from-europe-to-west-africa/): I get questions from all over the world. Like this one on October 19, 2020: Hi Daniel, I am trying to make sense of all the regulations regarding shipping dangerous goods for my PhD study and ended up on your website. Would you perhaps be able to clarify some things for me? Not sure if this is a problem if you specialize more in US regulations: I am looking for West/Central Africa to Europe exchanges! I am just going to start with what I hope to be a simple question: what are the restrictions for transporting ethanol (>70%) from Europe […]
- [FAQ: What is the satellite accumulation area (SAA)?](https://danielstraining.com/faq-what-is-the-satellite-accumulation-area-saa/): The Federal regulations of the U.S. Environmental Protection Agency (USEPA) and those of all states limit the amount of time a hazardous waste generator may accumulate hazardous waste on-site without requiring a permit for the facility to operate as a treatment, storage, or disposal facility (TSDF). In general, the on-site accumulation time limits for hazardous waste in a central accumulation area (CAA) are as follows: Large quantity generator (LQG) is allowed no more than 90 days for the on-site accumulation of its hazardous waste. A 30-day extension may be granted in extreme situations. Small quantity generator (SQG) is allowed no […]
- [Q&A: Can I use a UN Standard IBC for my non-HazMat?](https://danielstraining.com/non-hazmat-in-un-standard-ibc/): An email I received 10.21.20: Hello, Our company would like to know if the IBCs that are intended to be filled with non hazardous material need to be retested every 2.5 years. Does the DOT require this regardless of Hazardous / non hazardous material in the IBC? Thank you, My reply October 22, 2020: Thank you for contacting me. Please see below. An IBC (intermediate bulk container) used for the transportation of a hazardous material (HazMat) must be designed, manufactured, tested, and marked to indicate it meets a packaging specification of the USDOT/PHMSA. The United Nations Performance Oriented Standard (aka: […]
- [Q&A: Do I have to placard bulk tanks when they're empty?](https://danielstraining.com/placards-empty-bulk-packaging-hazmat/): The question, November 05, 2020: Good afternoon, I have a question about carrying bulk tanks. I recently got stop and was told that I was in violation because I didn’t have my placards showing with flammable material. I told the DOT officer that my bulk tanks were empty and that to my understanding that once you are empty you cant show your placards as flammable anymore. Well, long story short I got a ticket for not showing my placards as flammable even though the totes were empty. My question is… Is he correct on this? Thank you, Daniels Training Services, […]
- [The Requirements of 40 CFR 262.16(b)(9)(iv) Respond to Emergencies at Small Quantity Generator of Hazardous Waste](https://danielstraining.com/40-cfr-26216b9iv-respond-emergency-small-quantity-generator-hazardous-waste/): Federal regulations of the U.S. Environmental Protection Agency (USEPA) require a small quantity generator of hazardous waste (SQG) to maintain equipment and processes to prevent a hazardous waste emergency and to respond to it if one occurs. The regulations are found in the following SQG conditions for exemption: 40 CFR 262.16(b)(8) Preparedness and prevention 40 CFR 262.16(b)(9) Emergency procedures This article is the tenth – and final – in a series that closely examines and explains these regulations. In the previous article in this series I addressed the requirements of 40 CFR 262.16(b)(9)(iii) Ensure Familiarity with Emergency Procedures at a […]
- [The Requirements of 40 CFR 262.16(b)(9)(iii) Ensure Familiarity with Emergency Procedures for Small Quantity Generator of Hazardous Waste](https://danielstraining.com/40-cfr-26216b9iii-ensure-familiarity-with-emergency-procedures-small-quantity-generator-hazardous-waste/): Federal regulations of the U.S. Environmental Protection Agency (USEPA) require a small quantity generator of hazardous waste (SQG) to maintain equipment and processes to prevent a hazardous waste emergency and to respond to it if one occurs. The regulations are found in the following SQG conditions for exemption: 40 CFR 262.16(b)(8) Preparedness and prevention 40 CFR 262.16(b)(9) Emergency procedures This article is the ninth in a series that closely examines and explains these regulations. In the previous article in this series I addressed the requirements of 40 CFR 262.16(b)(9)(ii) Post Emergency Response Information at a Small Quantity Generator. That was […]
- [Q&A: Why does the E3 code indicate a dangerous good is not eligible for the De Minimus exception?](https://danielstraining.com/qa-why-does-the-e3-code-indicate-a-dangerous-good-is-not-eligible-for-the-de-minimus-exception/): Just two days before Christmas 2020 and I’m still getting questions like this: Greetings Mr. Stoehr, I hope this email finds you well and celebrating the holidays. I read the following requirement for shipping de minimis: “If the code isE1, E2, E4 or E5, the goods can be shipped as de minimis. If the code is E0 or E3 your dangerous goods cannot be shipped using this provision. What is the the reason why we cannot ship if the code is E3?  I understand if it is E0. E3 is similar to E2, only the maximum net quantity per outer package […]
- [Q&A: Do I need the HazMat and tanker endorsement for Class 9 in totes?](https://danielstraining.com/qa-do-i-need-the-hazmat-and-tanker-endorsement-for-class-9-in-totes/): A question from somewhere in America December 07, 2020: so I read a couple of your articles. we haul class 9 3082 16 totes about 40,000. does the driver need tanker and haz mat endorsement to haul. I know it needs placard. thanks, My reply on December 9th: Thank you for contacting me. Please see below for answers to your questions. I presume you are referring to the following two endorsements on the commercial driver’s license (CDL): Hazardous materials endorsement (aka: HazMat endorsement) Tank vehicle endorsement I also presume the “tote” you refer to is an intermediate bulk container (IBC) […]
- [Q&A: Is this a U-listed hazardous waste?](https://danielstraining.com/qa-is-this-a-u-listed-hazardous-waste/): It all started with a telephone conversation on 09.25.20 but spread into email correspondence (which I prefer). From the telephone conversation: Person had a waste Butanol Solution recovered from a spill. SDS indicated the following: 70-80% nonionic surfactant. 5-10% n-Butyl alcohol (CAS 71-36-3). Flash point of 130 degrees Fahrenheit. email correspondence began that same day: I did receive the SDS on the butyl alcohol and it turns out it is a Butanol Solution with a flash point of 130 F. The chemical composition is 70-80% Nonionic Surfactant and 5-10% Butyl Alcohol (the kind that is on the U-list). Do you […]
- [Q&A: How do I manage hazardous waste during months when my generator category changes?](https://danielstraining.com/qa-how-do-i-manage-hazardous-waste-during-months-when-my-generator-category-changes/): A question from someone who had contacted me previously (12.03.20): Hope you are doing well and enjoying the season so far 😊 I was hoping you could help me with another regulatory question regarding counting waste – or point me in the right direction. My question is about weekly inspections when a site becomes a SQG (200-2,200 lbs./mo.). Here’s the scenario: A generator became a SQG in October when hazardous waste was generated in that month and weekly inspections have been conducted since that time while the waste has been on site. The weekly inspections will be stopped once the […]
- [Q&A: Is it legal to hand write the UN numbers on a placard with a magic marker?](https://danielstraining.com/qa-is-it-legal-to-hand-write-the-un-numbers-on-a-placard-with-a-magic-marker/): Another one of the questions I get. This one in December of 2020: Is it legal to hand write the UN numbers on a black UN placard with a magic marker ? My reply: Yes. Maybe. Per 49 CFR 172.338, if more than one of the identification number markings displayed on placards, orange panels, or white square-on-points is lost, damaged, or destroyed during transportation, the carrier shall replace all missing or damaged identification numbers as soon as practicable. In such case the numbers may be entered by hand using an indelible marking material as long as it is legible. So, […]
- [Q&A: Is my waste a non-industrial waste in Texas?](https://danielstraining.com/qa-is-my-waste-a-non-industrial-waste-in-texas/): A question from a waste generator in the great state of Texas back in November of 2020: Hi, Daniel I work in a privately own Petro chemical lab. We serve the public and many big Oil companies. We test crude oil and gases for composition mostly. My question is we are should be listed as Non-industrial right? Thanks! My reply that same day: Thank you for contacting me. Please see below. Based on the regulations of the Texas Administrative Code (TAC) and guidance provided by TCEQ I believe the waste you generate qualifies as Industrial. Please see below: From a […]
- [The Requirements of 40 CFR 262.16(b)(9)(ii) Post Emergency Information for Small Quantity Generator of Hazardous Waste](https://danielstraining.com/40-cfr-26216b9ii-post-emergency-information-small-quantity-generator-hazardous-waste/): Federal regulations of the U.S. Environmental Protection Agency (USEPA) require a small quantity generator of hazardous waste (SQG) to maintain equipment and processes to prevent a hazardous waste emergency and to respond to it if one occurs. The regulations are found in the following SQG conditions for exemption: 40 CFR 262.16(b)(8) Preparedness and prevention 40 CFR 262.16(b)(9) Emergency procedures This article is the eighth in a series that closely examines and explains these regulations. In the previous article in this series I addressed the requirements of 40 CFR 262.16(b)(9)(i) Emergency Coordinator for a Small Quantity Generator. That was the first […]
- [The Requirements of 40 CFR 262.16(b)(9)(i) Emergency Coordinator for Small Quantity Generator of Hazardous Waste](https://danielstraining.com/40-cfr-26216b9i-emergency-coordinator-small-quantity-generator-hazardous-waste/): Federal regulations of the U.S. Environmental Protection Agency (USEPA) require a small quantity generator of hazardous waste (SQG) to maintain equipment and processes to prevent a hazardous waste emergency and to respond to it if one occurs. The regulations are found in the following SQG conditions for exemption: 40 CFR 262.16(b)(8) Preparedness and prevention 40 CFR 262.16(b)(9) Emergency procedures This article is the seventh in a series that closely examines and explains these regulations. In the previous article in this series I addressed the requirements of 40 CFR 262.16(b)(8)(vi) Arrangements with Local Authorities for a Small Quantity Generator. That was […]
- [Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators - Entry-Level Driver Training](https://danielstraining.com/minimum-training-requirements-for-entry-level-commercial-motor-vehicle-operators-entry-level-driver-training/): The Bullet: FMCSA established new minimum training standards for certain individuals applying for their CDL for the first time, an upgrade of their CDL, or a hazardous materials, passenger, or school bus endorsement for the first time. These individuals will be subject to the entry-level driver training (ELDT) requirements and must successfully complete a prescribed program of instruction before they will be permitted to take the CDL skills test or, in the case of the H endorsement, the knowledge test. Training must be provided by an entity that is listed on FMCSA’s Training Provider Registry (TPR). Who is subject to […]
- [Q&A: Will the HazMat Employee Training Required by PHMSA Satisfy the Requirement for ELDT?](https://danielstraining.com/qa-will-the-hazmat-employee-training-required-by-phmsa-satisfy-the-requirement-for-eldt/): Question: I’ve heard that entry-level driver training (ELDT) will be required as of February 07, 2022 for a driver seeking a hazardous materials (H) endorsement on their CDL for the first time. Can the HazMat Employee training required by PHMSA at 49 CFR 172.704 satisfy this new training requirement? Answer: No. First some clarification. The Final Rule for ELDT was published December 08, 2016 [December 08, 2016; 81 FR 88732]. It had an initial compliance date of February 07, 2020 but this was later extended to February 07, 2022. The rule created new training standards for each of the following: […]
- [FAQ: How do I register to be placed on FMCSA's Training Provider Registry (TPR)?](https://danielstraining.com/faq-how-do-i-register-to-be-placed-on-fmcsas-training-provider-registry-tpr/): Before we begin… In a flurry of proposed rules, final rules, amendments to the final rule, effective dates, compliance dates, and then an extension of the compliance date, the Federal Motor Carrier Safety Administration (FMCSA) within the U.S. Department of Transportation (USDOT), mandated entry-level driver training (ELDT) for certain drivers seeking a new or updated commercial driver’s license (CDL) or those seeking certain endorsements to their CDL for the first time. Read: Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators – Entry-Level Driver Training As part of this new rule FMCSA created a training provider registry (TPR) to both […]

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