49 CFR 173.12 contains many exceptions to full regulation for shipments of hazardous waste in a lab pack. In an earlier blog post I discussed the exception in 173.12(d)that removes the need to include the technical name of a hazardous…
Management of Alkaline Batteries
Batteries are one of those items that we are so used to seeing in our home life, that we sometimes forget that these can be generated as a waste at our place of work. In the course of a day…
Applicability of the HMR to HazMat Unloading Operations
A HazMat Employee is defined at 49 CFR 171.8 as a full-time, part-time, temporary, or self-employed person who in the course of employment directly affects hazardous materials transportation safety. This includes but is not limited to persons who: Load, unload, or handle hazardous materials.…
US DOT Requirements for the Shipment of Empty HazMat Packagings
It’s quite likely that at one time or another you have had to deal with the off-site shipment of empty packagings. Most manufacturing facilities experience this when they empty various non-bulk (usually 55-gallons or smaller) packagings of their contents and…
Selecting a Carrier for Your Shipment of Hazardous Materials
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…
When Must an Identification Number Not be Included on a Hazardous Material Placard?
An identification number, though usually displayed on or in association with a placard on a vehicle or bulk container, must be in compliance with the Marking requirements of 49 CFR 172, Subpart D and not the Placarding requirements of Subpart…
Non-Routine Shipments of Hazardous Materials
“Other than hazardous waste, we don’t ship hazardous materials, so we don’t need the DOT HazMat Employeetraining for our Shipping Department personnel.” The preceding statement may be true when its ‘business as usual’, but there are a few situations that arise…
Use of Commas in the Proper Shipping Description for Hazardous Materials
A question from an attendee of one of my recent training events forced me to re-think my strongly-held belief in the correct formatting of the proper shipping description for a hazardous materials shipment. The question asked was, “Is a comma…