The Bullet: Due to the COVID-19 public health emergency, USDOT/PHMSA issued a notice of enforcement discretion to allow for the filling and transportation of DOT-specification cylinders with Division 2.2 Non-Flammable Gas when overdue for their periodic requalification by no more…
The Specification Packaging Marking Requirements of 49 CFR 178.3
Most packagings intended for the transportation in commerce of a hazardous material must be designed, manufactured, and tested to meet either a DOT specification or a UN standard, which is then known as a specification packaging (Don’t confuse “specification packaging”…
Question Regarding Containers for Universal Waste Lamps
From a past attendee of one of my Training Seminars – now defunct – on May 19, 2015: Dan, I seem to recall hearing that the EPA does not like the telescoping boxes for used lamps. I can only assume…
Reuse of HazMat Packaging for the Shipment of Hazardous Waste
The reuse, reconditioning, and remanufacture of hazardous material packagings (both bulk and non-bulk) is addressed at 49 CFR 173.28 of the PHMSA/USDOT Hazardous Material Regulations. In general packagings and receptacles (bulk and non-bulk) used more than once must be in…