Q&A: Is the transport of oil (new and used) subject to USDOT regulations as a HazMat?

Q&A: Is the transport of oil (new and used) subject to USDOT regulations as a HazMat?

A question from a concerned truck driver (01.10.18):

I drive lube truck and carry 600 gal go new oil and 400 gal used oil in <<state>> and surrounding states my company told me to remove placards saying not needed. I am questioning them and can’t find answer if I am legal.

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://www.danielstraining.com/

My answer (01.10.18):

Thank you for contacting me.  I will try to answer your question below.

  • I cannot be certain without viewing the safety data sheet (SDS) or some other technical data, but it is unlikely that oil – new or used – will meet the definition of a hazardous material per USDOT regulations.
  • If not a HazMat the display of USDOT placards is not required.

I hope that answers your question.  Please don’t hesitate to contact me with any other questions.

Conclusion:

Easy but illustrating a very common issue in the regulated – or not regulated – community.  Before you can begin to consider the regulations applicable to the transportation of a hazardous material: hazard communication, packaging, training, load securement & segregation, & more; you must classify the article or substance according to the USDOT/PHMSA’s definition of a hazardous material.  No hazardous material, no Hazardous Materials Regulations.

It’s possible you transport or offer for transport both HazMat and non-HazMat.  My training and consulting services can help you to identify the difference.