Question (April 13, 2018):

Hi Daniel,

I had a quick question about the DOT Registration requirement (Subpart G).

If a SQG of HW ships their waste (e.g. 3 drums >1001 lbs -needs placard) with Safety Kleen, the SQG needs to be registered?

Thanks

My answer that same day:

In the situation you describe, registration will be required. The hazardous waste generator status of the shipper is not a factor when determining if registration with PHMSA is necessary.

Please read: Have you Registered with PHMSA as a shipper of HazMat?

Thank you and please contact me with any other questions.

Conclusion:

So that was easy.  Please see below for some information on things left unsaid in that brief Q&A.

• The customer asked about “DOT” but I answered as “PHMSA”; what gives?  The Pipeline and Hazardous Material Safety Administration (PHMSA) is one of thirteen (13) administrations within the U.S. Department of Transportation (DOT). PHMSA is responsible for ensuring the safe and secure movement of hazardous materials by all modes of transportation: highway, rail, vessel, aircraft. It therefore has overlapping authority with other administrations and bureaus within the DOT such as: Federal Aviation Administration (FAA), Federal Railroad Administration (FRA), Federal Motor Carrier Safety Administration (FMCSA), and others. Its authority may also overlap with the US Coast Guard. Note: while the Coast Guard is no longer a part of the DOT, it operates under a memorandum of understanding to enforce DOT regulations for transportation by vessel.  In casual conversation it’s OK to refer to USDOT regulations but if we’re trying to be precise we must use PHMSA or USDOT/PHMSA.
• SQG?  This is a small quantity generator of hazardous waste.  A SQG generates more than 100 kg (220 lb) per month of hazardous waste but must not generate more than 1,000 kg (2,200 lb) per month.  Under USEPA’s hazardous waste regulations a SQG is subject to a moderate level of regulation, between that of a large quantity generator (LQG) and the very small quantity generator (VSQG).

If you are a generator of a hazardous waste subject to USEPA and state regulations you are likely also to be a shipper of hazardous materials (USEPA hazardous waste is one type of hazardous material) subject to USDOT/PHMSA regulations for its off-site transportation.