I have the opportunity during my weekly nationwide training events to meet with a variety of HazMat Employers who usually are also Shippers, since they “offer for shipment” a hazardous material to a Carrier who then transports it in commerce. For most persons, their experience as a Shipper of hazardous materials is limited to their routine shipments of hazardous waste. For this purpose they commonly rely on the hazardous waste disposal firm or TSDF to provide for off-site transportation of the waste.
Sometimes however, a person is faced with the responsibility of arranging for a non-typical HazMat shipment. In this situation you will need to select a Carrier that can transport the hazardous material to its destination. It is important to select a Carrier who meets the requirements of both the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Motor Carrier Safety Administration (FMCSA). Both of these are administrations within the US Department of Transportation and require a brief explanation.
PHMSA was created in 2005 to replace the Research and Special Provisions Administration (RSPA). It is used by US DOT to develop and enforce regulations to ensure the safe transportation of hazardous materials (HazMat) in commerce by air, water, highway, rail, and all transportation by pipeline.
FMCSA was formed January 1, 2000 to regulate the trucking industry in the US. Its regulations apply to employees and employers who transport HazMat – and non-HazMat – in commerce on public highways.
Whether it is a routine shipment of your hazardous waste that you have shipped a thousand times before, or a one-time or first-time shipment, you as the Shipper must ensure the Carrier you select is in compliance with all applicable regulations of the PHMSA and FMCSA. Before you offer a hazardous material for shipment, confirm the following with your Carrier:
- Has the driver received training as a HazMat Employee per the requirements of 49 CFR 172, Subpart H within the last three years? All HazMat Employees must receive the following training:
- General Awareness/Familiarization
- Function Specific
- Safety Procedures/Emergency Response
- Security Awareness
- In-Depth Security (if applicable, see here for more information)
In addition to the above, a person who transports hazardous materials over a public roadway must receive Driver Training.
- If the shipment is required to be placarded per the requirements of 49 CFR 172, Subpart F or otherwise meets the applicability requirements of 49 CFR 107.601; is the Carrier registered as a transporter of hazardous materials per the requirements of 49 CFR 107.608? Click here for a short survey to determine the registration requirements.
- If the shipment meets the applicability requirements of 49 CFR 172.800(b) – Revised effective October 1, 2010 – does the Carrier have a DOT Security Plan and conduct In-Depth Security Training for its HazMat Employees per 49 CFR 172, subpart H?
- If the shipment is required to be placarded per the requirements of 49 CFR 172, Subpart F; does the driver have the hazardous materials endorsement on their Commercial Driver’s License (CDL) per their respective state to the minimum standards mandated in 49 CFR 383, Subparts G & H?
- If the shipment meets the applicability requirements of 49 CFR 385.403; does the Carrier have a Hazardous Materials Safety Permit (HMSP)? A Carrier may take the following survey to determine if it is required to obtain an HMSP. A Shipper may find this survey useful as well.
The selection of your Carrier is only the first of many of your responsibilities as a Shipper of hazardous materials. You’re responsibilities include:
- Determining the Proper Shipping Name, Hazard Class and/or Division, Identification Number, and packing group.
- Select the proper packaging.
- Affix the proper hazard class labels and markings.
- Properly complete the shipping paper, including the…
- Emergency response information
- Emergency response phone number
- Certification statement and signature
- Provide correct placards to the driver.
- Completion of a DOT Security Plan. Take this simple survey to see if the DOT Security Regulations apply to you.
- TRAINING FOR ALL OF YOUR HAZMAT EMPLOYEES.
Everything you need to know as a Shipper is covered in the afternoon session of my one-day, nationwide training events. It also fulfills the US DOT triennial training requirements for HazMat Employees. The remaining 4-hours cover the Hazardous Waste Personnel training requirements of the US EPA and provides a wealth of information for generators of hazardous waste.