A question (12.12.17):

Hello,

As part of the power industry we come into contact with materials containing PCB’s. My question is prior to a sample being taken, therefore assuming it is indeed PCB contaminated, does that require the HazMat endorsement for our drivers? I saw a previous response you gave stating it directly related to the amount of PCB’s in the object, but it is much easier to take samples and test materials after they have been transported back to our facility. Will that require the special licensure?

Thanks.

My answer the same day:

Thank you for contacting me.  I am happy to answer your question.  Please see below.

• PCBs and PCB-contaminated materials are a Reportable Quantity (RQ) of a hazardous substance if there is at least 1 lb of PCBs in the package (the RQ of PCBs is 1 lb).  This is a result of the concentration and the total weight of oil in the package:
  • Lbs of oil x % PCBs in oil = Lbs of PCB in package.
  • Read this past Q&A:  How can I transport PCB transformer oil?
• If a Reportable Quantity of a hazardous substance is present, the material is a hazardous material per USDOT/PHMSA Hazardous Materials Regulations.
• If it does not meet the defining criteria for any of the first eight hazard classes, then it will be a Class 9 Miscellaneous hazardous material.
• A Class 9 Miscellaneous does not require the display of placards on the vehicle when transported within the U.S.  Read: Is the Class 9 Placard Required?
• If placards are not required on the vehicle, then the hazmat endorsement is not required on the CDL.  Indeed, depending on the size of the vehicle and if it crosses state lines it may not be a commercial motor vehicle at all.  Read more about Commercial Motor Vehicles
• Hazmat employee training is required for anyone involved in the transport of a hazardous material.
• The operator of a motor vehicle that transports hazmat requires hazmat employee training and an additional component for Driver Training.  Driver training is not required if the hazmat endorsement is maintained on the CDL.
• The Materials of Trade exception will provide you relief from most hazmat regulations (even training!) if applicable.  Read:  The Materials of Trade Exception.

In sum: