The question came by way of a telephone conversation on August 28, 2017 (no transcript available).  A gentleman was interested in the transport of asbestos waste – a hazardous material per USDOT/PHMSA regulations if friable – in California.  He needed to know if the transport in commerce of asbestos waste was subject to California regulations as a commercial motor vehicle (CMV).  I had the time to research the California regulations (this isn’t my usual area of expertise) and fire off to him some information in an email that same day:

• Title 13 of the California Vehicle Code (CVC) part 260 defines a commercial vehicle:

A commercial vehicle is a type of vehicle:

• Used or maintained for the transportation of persons for hire, compensation, or profit (for example, a taxi or limousine).
• Designed, used, or maintained primarily for the transportation of property.

Types of motor vehicles include but are not limited to:

• Motor Truck (CVC 410)
• Pickup (CVC 471)

Per 13.005, commercial vehicles must be registered – and pay fees – based on their gross vehicle weight (GVW).

Based on the above it appears that the California definition of a CMV (aka: Regulated Vehicle) is more strict than the Federal regulations or other states.

Also:

• The transporter of a hazardous waste (RCRA or non-RCRA) must be registered with DTSC.
• CVC §15278(a)(4) requires a HazMat endorsement for those who drive a vehicle requiring placards.
• As noted earlier, asbestos as a Class 9 Miscellaneous is not required to display placards.
• Other hazardous waste (both RCRA & non-RCRA) may require the display of placards depending on the quantity.
• On the CHP website is a good tool for determining compliance:  The Terminal Manager’s Compliance Checklist (CHP 800D)
  • A bullet point under #31 of the checklist indicates the need for HazMat Employee training (I provide this training).
• For more information contact the CHP at 916.843.3400.

I hope this helps.  Please contact me if you require any additional information.

That seemed to satisfy him.

The transportation in commerce of hazardous materials – which includes asbestos waste – is subject to the regulations of several agencies:  OSHA, for the potential exposure to employees; USEPA, to reduce the impact of its disposal on the environment; USDOT/PHMSA, for its safe transportation on public roadways; and those of your state if the transportation is for a business.  Some states, like California, have even more strict regulations for the operation of commercial motor vehicles (CMVs).