Are You Required to Have IMDG Training?

Are You Required to Have IMDG Training?

Recently one of our clients had a shipment of their product rejected at a port in Europe.  They had been sending it there for years without incident, but this time was different.  Inspectors chose to verify their paperwork and they were missing crucial IMDG dangerous goods paperwork.  All methods of hazardous materials transportation have specific training requirements, but the one which often catches people by surprise is IMDG.

If you ship hazardous materials by vessel or over water, you are required to follow the rules of the International Maritime Dangerous Goods (IMDG) code.  This includes companies who are:

  • Loading shipping containers onsite;
  • Using third-party companies to load shipping containers for them onsite; and,
  • Sending hazardous materials to freight forwarders or third-parties to be loaded somewhere else.

You May Qualify Without Knowing It

Shipping containers are used for overseas transport, but also keep in mind they are used to transport products to U.S. states such as Hawaii and Alaska as well as U.S. territories.  For example, a different client of ours was responsible for gathering together all the products needed for opening a new Wal-Mart store, and some of those were hazardous materials.  When there were new Wal-Marts to open in Alaska and Hawaii, those products needed to be loaded into shipping containers.  As a result, that company became subject to the rules of IMDG.

Keep in mind that even small quantities can trigger requirements.  For example, we have clients who send vehicles and farm implements via vessel.  Along with the vehicles are boxes of oils and lubricants for operation once they are unpacked.  This triggers hazardous materials regulations.  Even residual fluids left over in the engines that got there when the factory tested it to make sure it worked triggers hazardous materials regulations.

Just like in DOT regulations for ground shipments and IATA regulations for air shipments, goods loaded into the containers must be packaged in certified packages that have design qualification reports for them.  Special IMDG dangerous goods paperwork called a Dangerous Goods Transport Document is also needed to accompany the shipment and all packages and the container need to be labeled and placarded accordingly. 

Even if you use a third-party to handle this for you, it’s still your company’s responsibility to make sure they are complying with the rules as you are the shipper and it’s your company who will be dealing with the regulators and with potentially unhappy customers the further the goods are delayed.

Training Requirements

If IMDG applies to your operations, the following personnel need to have training upon employment or assignment to hazardous materials duties:

Anyone who…

  • Classifies and/or identifies the proper shipping names of dangerous goods (hazardous materials);
  • Packs dangerous goods;
  • Marks, labels or placards dangerous goods;
  • Load/unload dangerous goods;
  • Prepare transportation documents;
  • Offers or accepts dangerous goods for transport;
  • Handles, loads or unloads dangerous goods into or from ships;
  • Prepares dangerous goods loading/stowage plans;
  • Carries dangerous goods in transport;
  • Enforces, surveys or inspects dangerous goods for compliance; and is,
  • Otherwise involved as determined by a competent authority.

As with other hazardous materials training, students are required to have general awareness, safety, and function-specific training.  Refreshers are required every 3 years.

Does this requirement apply to your company?  iSi has regularly scheduled IMDG courses and can provide them onsite on your own schedule, at your own convenience.  Check here for our course schedule or contact us here for more information and pricing for an onsite class at your facility!

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What the Haz?

What the Haz?

A Deeper Dive Into the “Haz” Words in OSHA, EPA and DOT and Where They Can Crossover

Every once in a while, we will get a call from someone looking for “Hazmat” training.   To you, the word hazmat may mean one thing, but we guarantee to someone else it probably means something completely different.

iSi’s mission is to help companies navigate compliance with EPA, OSHA and DOT regulations.  Once you start familiarizing yourself with those regulations, you will find that the definition of hazmat can be different for different agencies and different situations.   You will also see that there are a number of words that include “haz” that can creep into the picture and be used interchangeably.  An even deeper dive will show that each agency will either make up their own definition or borrow from one another.

Each Agency Has Its Own Focus

Regulations and their definitions are typically written in the perspective of the focus of the agency.  Each agency has its own role to play in the workplace and how they use their haz words will often be reflective of that.

  • OSHA – OSHA’s focus is safe and healthful working conditions for workers
  • EPA – EPA’s focus is on human health and the condition of the environment
  • DOT – DOT’s focus is on the safe, efficient, sustainable and equitable movement of people and goods

Once you know the perspective for each, that will help you be able to better understand regulations when they crossover or refer to one another.

Hazmat

Hazmat is a shortened version of “hazardous materials.”  Each agency refers to hazardous materials a little differently.

In OSHA, the term hazmat can refer to hazardous materials or hazmat teams.  OSHA says a hazardous material is something that can be a health hazard or a physical hazard.  However, a hazmat team is an organized group of employees who perform work to handle and control spills or leaks of hazardous substances.  Individually trained members of the hazmat team are called hazardous materials technicians.  Later we’ll look at the OSHA HAZWOPER standard where many of these definitions are found.

To DOT, hazmat means “a substance or material capable of posing an unreasonable risk to health, safety, and property when transported in commerce…”  It also can include hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials listed in the Hazardous Materials Table, and materials meeting their criteria for hazard classes and divisions. The term Hazmat employee in the regulations are those persons who package or prepare, physically transport, load, unload, design or makes packages for, fills out paperwork for or ensures the safe transportation of hazardous materials.

To EPA, a hazardous material is any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

From the definitions, you can see that OSHA was focused on people, DOT was focused on transportation and EPA was focused on the environment.

HazCom

Another shortened haz word is HazCom.  This is short for the OSHA Hazard Communication Standard.  This standard is all about hazardous chemicals, that is, any chemicals that are a physical or health hazard. The HazCom Standard deals with Safety Data Sheets (SDS), labeling, markings, training and more.

EPA’s Emergency Planning and Community Right to Know Act, or EPCRA, regulations refer to OSHA’s hazardous chemicals when it comes to which chemicals apply to the EPCRA regulation.  Those which fall under the HazCom standard and have SDSs associated with them are included in EPCRA reporting requirements.  Some companies also refer to HazCom training by the term Employee Right to Know training.

Hazardous Waste

Another haz is hazardous waste. The term hazardous waste comes from EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.  There’s a lengthy determination process one must go through to even determine if something can be defined to be a hazardous waste.  You’ll see all of those criteria and the roadmap in the definition of hazardous waste at 40 CFR 261.2.

EPA’s website says, “Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and may come in many forms, including liquids, solids gases, and sludges.”

Hazardous waste must be discarded and must be a solid waste.  To be a solid waste, it must be a material that has been abandoned, recycled, is inherently waste-like or is a military munition.

Once you determine that it’s discarded and a solid waste, there are another set of questions to ask to make the determination if a waste is hazardous or not.  This process is quite important and is required to be completed and documented for each of your wastes.

OSHA mentions hazardous waste in their HAZWOPER standard, calling hazardous waste anything that’s found to be a hazardous waste by the EPA definition or anything that DOT calls a hazardous waste in their definition.

In DOT regulations, DOT says hazardous waste is defined under EPA’s definition and that to ship hazardous waste a hazardous waste manifest is required.  Hazardous waste is a hazardous material that is regulated for transportation. So when a vendor comes to pick up your hazardous waste, your company is the one technically shipping it and are therefore subject to all of the DOT hazmat regulations the same as if you were shipping any other hazardous material.

Hazardous Substances

All 3 agencies use the term hazardous substance.

In EPA, a hazardous substance is “Any substance, other than oil, which, when discharged in any quantities into waters of the U.S., presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, shellfish, wildlife, shorelines and beaches (Section 311 of the Clean Water Act); identified by EPA as the pollutants listed under 40 CFR Part 116.”  Hazardous substances are referred to in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, aka Superfund), the Clean Water Act (CWA), the Clean Air Act (CAA), the RCRA hazardous waste regulations, and the Toxic Substances Control Act (TSCA).

OSHA makes it easy.  They say a hazardous substance is whatever EPA CERCLA says it is, whatever DOT says are hazardous materials, whatever EPA says a hazardous waste is, or any other biological or disease-causing agent that could lead to things like death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions or physical deformations in such persons or their offspring.

DOT says a hazardous substance is a hazardous material when that material is listed in their Appendix A and when its single package exceeds the reportable quantity listed in the Appendix. They also have other considerations if it’s a mixture or solution or a radionuclide.

HAZWOPER

And finally, there’s HAZWOPER.  Although it’s one of our more popularly discussed haz words, we left this for the end because this regulation actually uses all of the haz words in one place and seems to be one standard that incorporates so many different requirements from all 3 agencies within it.

HAZWOPER stands for Hazardous Waste Operations and Emergency Response.  HAZWOPER is found in the 1910 General Industry Standards under Subpart H, Hazardous Materials.  An identical copy can be found under a different subpart in the 1926 Construction Standards.

There are 3 main pieces or goals to HAZWOPER:

  1. Rules for conducting cleanup operations at sites determined to be EPA RCRA hazardous waste cleanup sites, cleanup operations at sites contaminated by hazardous substances on uncontrolled hazardous waste sites that EPA or another government agency have required to be cleaned up, or conducting voluntary cleanups at those same types of uncontrolled waste sites;
  2. Operations at treatment, storage and disposal facilities (TSD) regulated by EPA RCRA; and,
  3. Emergency response to releases of hazardous substances at any facility, any location.

Being an OSHA regulation, HAZWOPER is all about protecting the worker and the public during the cleanup, so all the guidance centers around preparing for and safely cleaning up hazardous substances.

The regulation mentions the term Hazmat teams in relation to those responding to the emergency responses found in part 3 of the standard.

HAZWOPER says any materials cleaned up and containerized into drums must meet appropriate regulatory requirements for DOT transportation, RCRA hazardous waste and OSHA safety regulations.  Waste must be transported per DOT regulations while self-contained breathing apparatuses used by workers to protect themselves during work are to comply with DOT standards.

The DOT’s Emergency Response Guidebook is mentioned and often consulted for emergency response information and guidance.

If a company has prepared a contingency plan per EPA requirements and that plan includes emergency response information, the company can use that contingency plan as part of its emergency response plan so that efforts are not duplicated.

On the EPA side, because OSHA regulations don’t apply to local and state governments, EPA has adopted the HAZWOPER standard into 40 CFR 311 to apply to those local and state governments and any of those not covered by a state OSHA-approved plan.

Also in EPA, emergency spills trigger a whole host of reporting requirements as well as emergency response plans and training to protect the environment from hazardous waste spills, oil spills, pipeline leaks and chemical releases to water, air or land.

Conclusion

This is not an exhaustive list of haz references or examples where all 3 agencies cross over, but hopefully it gave you an idea of how these terms and the rules related to them can be so different in some cases, but so intertwined in others.  The haz words used can differ depending on the situation.

So, if you call us asking for hazmat training, you’re likely to get a lot of questions from us about your end goal.

What haz words have you come across?  What examples did we miss?  We’ll be posting this on our Facebook, LinkedIn, Twitter and Instagram pages.  We’d love to hear from you!  

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Lithium Batteries: Safety Hazards and Their Impact on Businesses

Lithium Batteries: Safety Hazards and Their Impact on Businesses

More lithium and lithium-ion batteries are being used in products today and just like any material, if we understand how to use it safely, it should not pose any problem. (Note: Lithium batteries are single-use batteries and lithium-ion batteries are the rechargeable kind.)

Lithium-containing batteries, when damaged. defective or used improperly, can present a fire and/or an explosion hazard.  Small items such as a laptop can typically have 6 lithium cells in them, while an electric vehicle can use 7,000 lithium-ion cells. This change in size greatly increases the risk and effects of a fire. If an electric vehicle catches on fire in your garage, you most likely do not have a way to deal with a 3,632° F fire.

Should I Really Worry About My Battery Catching on Fire?

If your battery stays intact, and does not allow moisture to get inside, or as long as there is not an issue with overcharging where the temperature runs away, you should be fine. The issue is that lithium and water don’t like each other. In fact, in its pure form, water causes lithium to react, sometimes violently, creating sparks and lots of heat, as well as hydrogen gas.

Lithium-ion batteries are a little different than the pure form of lithium in that they are filled with a lithium compound, and not pure lithium. Because of this, the material in many batteries are not quite as active with water. But when you have 7,000 cells in one place, if one catches on fire, a chain reaction can occur that you cannot control. Also fighting that fire with water may not be the best solution when water can cause it to react more.

This can be the same for industry. Lithium-ion batteries are being used in everything from pumps and instruments, to cars and equipment, hand tools, computer servers, and so many more products. Even your wireless mouse may have lithium-ion batteries.

If you just throw that away in the trash, not only are you potentially violating waste regulations and DOT shipping regulations, you may also be creating a fire hazard for the waste removal truck the landfill that it goes to.

DOT Issues Advisory Warning for Lithium-Containing Batteries

Recently DOT has found the issue with shipping lithium-containing batteries for recycle or waste has gotten out of hand. The Pipeline Hazardous Materials and Safety Administration (PHMSA), which is the HazMat division of the DOT, has issued a safety advisory on the dangers to help people out. The advisory warns that shippers and carriers need to take extra (and sometimes different) precautions when shipping damaged, defective or recalled lithium-containing batteries.

During recent compliance inspections, DOT inspectors have been finding improperly packaged and shipped lithium-containing batteries for disposal or recycling.  Some examples include:

  • Not packaging to prevent short circuiting
  • Mixing damaged batteries with others in the same packaging for recycling/disposal
  • Shipping pallets of batteries in boxes and drums with inappropriate package identifications

From a hazardous waste perspective, EPA recommends that lithium batteries be managed under the Universal Waste regulations.

Battery Disposal Rules – for Consumers

Regular citizens should take used, damaged, defective or recalled lithium-containing batteries to recycling facilities geared for accepting them, or your local household hazardous waste collection point. Do NOT throw them away with your other garbage.  If there is an item that’s recalled that has the battery in it, follow the manufacturer’s safety instructions and disposal instructions. Pay attention to any warnings.

Find an authorized provider to ship any lithium-containing batteries because they are considered to be hazardous materials.  When the post office asks if you are shipping hazardous materials, lithium-containing batteries makes that answer yes.

Battery Shipping and Disposal Rules – for Businesses

If you are a business, there are a number of regulations you need to follow to properly deal with lithium-containing batteries.  First, they can only be shipped by ground methods, so that’s by truck, rail or vessel. Overnight shipments or any shipment that could potential go via air methods are out of the question.

There are also specific regulations and procedures you need to follow to properly package, label and ship them.  There are regulations about the type of box you send them in because those packages must have special permits for this role.   There are special labels and markings that need to go on the packages and special ways they need to be packaged. Workers who will be participating in any function of the process are required to have proper training specific to their role, and that training is required every 3 years.  Emergency response information must also be included in the package process.

Training and Consulting Resource

iSi conducts hazardous materials shipping for businesses as well as conducts training to properly ship hazardous materials via ground, air, and vessel.  If you are a business that has question about how to deal with your lithium-containing batteries or if your workers need training, contact us today!

Need Help?

iSi can help with lithium battery issues as well as employee training!

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

As a former corporate environmental, health and safety manager, Ryan has a vast experience in working with both environmental and safety compliance issues in multiple states.  His specialties include national and international dangerous goods transportation, hazardous waste, environmental compliance, industrial hygiene and safety compliance. He is also an ISO 14001 Lead Auditor.

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Who Needs DOT Hazmat Training?

Who Needs DOT Hazmat Training?

Photo of a person preparing a hazmat package for proper shipping.

Often we get the question, “Who needs DOT hazmat training?”  Not only are there nuances between the various agencies of DOT and the international transportation organizations DOT defers to, but often in companies there could be a number of people involved in the process – knowingly or unknowingly.

Basically, anyone involved in the process of sending hazardous materials (hazmat) will need to be trained. This would include anyone who:

  • Purchases the packaging and/or determines it’s the correct packaging for your materials;
  • Prepares the package for sending (boxes, labels, determines which box to use, etc.);
  • Fills out the paperwork, choosing labels or choosing placards;
  • Signs off on manifests or paperwork (including sending hazardous waste);
  • Loads, unloads, and handles hazmat;
  • Sells, tests, reconditions, repairs or modifies packaging for use in shipping hazmat;
  • Screens baggage, cargo, or mail;
  • Transports hazmat or operates a vehicle transporting hazmat;
  • Is a freight forwarder who accepts/transfers/handles/unloads cargo; and,
  • Anyone who supervises or conducts training for any of the above personnel.

Who Could be Involved?

So this could involve multiple departments or people at your company.  Roles such as:

  • Shipping & Receiving
  • Mailroom Clerks
  • Environmental, Health and Safety People
  • Hazardous Waste Handlers/Manifest Signers
  • Administrative Staff
  • Procurement/Purchasing and Finance
  • Warehouse
  • Plant Personnel
  • Operations Management

Take a look at your process. Who’s involved? Do they need to be involved? Have they been trained?

Training Content

DOT training is required by 49 CFR 100-185.  49 CFR regulates all hazmat shipments for the following agencies of the Department of Transportation:

  • Pipeline and Hazardous Materials Security Administration (PHMSA)
  • Federal Aviation Administration (FAA)
  • Federal Motor Carrier Safety Administration (FMCSA)
  • Federal Railroad Administration (FRA)
  • State agencies with authority to enforce DOT regulations

Your training content is required to include general awareness, security awareness, safety and then function-specific training to the role each person is doing in the process.  So the training durations could be different for different roles.

What if Someone Ships Hazmat For You?

Even if you have a third-party do the packaging for you, your company is still the shipper of record. That means anyone involved in the process from your end, even if it’s just one person signing paperwork that your vendor prepares, will need training.  By signing paperwork, that employee is legally certifying the hazmat is properly packaged and ready for transport. This would apply to companies you use for hazardous waste transports, crate building, or freight forwarding.

Planes, Trains and Automobiles (and Ships)

If your packages are going by ground, that is, truck or train, you’ll need DOT training with refreshers every three years. There are additional railroad regulations that need to be covered if you’re shipping by rail.

If packages are going by plane, such as overnight service, you’ll need separate IATA training with refreshers every two years. Please note that unless you specify your hazmat as “ground only”, there’s a possibility it could be put onto an airplane.  IATA has their own set of regulations in addition to the DOT, and air regulations are also covered in 49 CFR.

If packages are going on a ship, you’ll need IMDG training with refreshers every three years. This not only includes overseas shipments, but shipments to U.S. states such as Hawaii and Alaska or territories like Puerto Rico.

For more information about how the agencies work together, read our blog article, “Who Regulates Hazmat Shipments?”

If you need help sorting out who should be trained, or if you have employees you know need training or refreshers, contact us and we’d be happy to help! Check out our current hazmat shipping training schedule.

 

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Annual DOT Registrations Due July 1

Annual DOT Registrations Due July 1

If your company ships hazardous waste or hazardous materials in certain types and/or quantities, you are be required to register with the Department of Transportation (DOT) annually.

Who Needs to Be Registered With DOT?

DOT registrations are required for companies or individuals shipping the following items:

  • A quantity of hazardous material/waste that requires placarding.
  • A hazardous material (including hazardous wastes) in a bulk packaging having a capacity equal to or greater than 3,500 gallons for liquids or gases or more than 468 cubic feet for solids.
  • A shipment in other than a bulk packaging of 5,000 pounds gross weight or more of one class of hazardous materials (including hazardous wastes) for which placarding of a vehicle, rail car, or freight container is required for that class.
  • A highway route controlled quantity of a Class 7 (radioactive) material by highway, rail, air, or water.
  • More than 55 pounds of a Division 1.1, 1.2, or 1.3 (explosive) material by motor vehicle, rail car, or freight container.
  • More than 1 liter/1.06 quarts per package of a “material extremely toxic by inhalation.”

State and federal agencies, Indian tribes, farmers, and individual truck drivers are exempt from registration. Government contractors must register, as do any farmers who transport hazardous materials not used in farming or truck drivers who aren’t driving a truck already registered by a motor carrier.

How Do You Get Registered With the DOT?

DOT registrations are conducted online or you can fill out a form and mail it in. There will be a fee for registration. Registration fees are determined by your company’s size, that is, whether or not you are considered to be a small business by the U.S. Small Business Administration. You will need to know your company’s primary NAICS code. Once you determine your NAICS code, you’ll be able to determine if you meet the small business size standard. Fees can range from $275/year for a small business to $2,600 for a large business, with slight discounts for registering for up to 3 years at a time.

Your company cannot transport hazardous materials until registered. If your company has failed to register for any previous years, you will need to register for any missed years and pay for those as well.

What is Required for DOT Registration Recordkeeping?

Once registered, you’ll receive a Hazardous Materials Certificate of Registration. This will have your DOT registration number, year, date issued, and expiration date. Those who register online can choose to print out their certificate, or have one mailed. Copies of your registration forms and certificate must be kept on file for 3 years and may be asked for during an inspection. Any trucks, truck tractors, or vessels must have a copy of this certificate or another document with your current DOT registration number on it.

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2020 ERG – Emergency Response Guidebook Updates

2020 ERG – Emergency Response Guidebook Updates

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Download a PDF Summary

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Purchase an ERG Today

Purchase a copy of the 2020 ERG from our online store!

The new 2020 version of the Emergency Response Guidebook (ERG) is finally out, and hard copies are now available.  The ERG is published every 4 years.

What is the ERG?

The ERG contains emergency response information and is a handbook used by emergency and hazardous materials incident responders, truck drivers, railroad personnel, pipeline personnel, pilots, police and firefighters.  It is written and updated by four separate international agencies:

  • U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Transport Canada’s Canadian Transportation Emergency Centre (CANUTEC)
  • Argentina’s Chemistry Information Center for Emergencies (CIQUIME)
  • Mexico’s Secretariat of Communications and Transport

iSi uses the ERG in our HAZWOPER training as well as our DOT Hazardous Materials Transportation, Hazardous Waste Management and RCRA Refresher classes.  This is because handling emergency spills are a component of all of these classes.

Updates

The four agencies have been working on this latest version since 2017.  In 2018, all of the agencies solicited input from their public through calls for comment, listening sessions, online surveys, and articles.  From these solicitations, 100 comments were gleaned to be considered for incorporation and DOT held a public meeting as well.  Since then, sub-groups worked on the updates.

Here is a list of the planned changes and items that were up for review within each section of the book. The agencies will:

White Pages [General Information, Instructions, Recommendations, Guidance]

      • Review content for use of plain language;
      • Improved quality of illustrations in charts for railcar and road trailer identification;
      • Add new lithium battery markings;
      • New terms in the glossary section;
      • Add a decontamination section; and,
      • Add basic information about heat induced tears (HIT).

Orange Pages [Response Guides]

      • Comprehensively review of all materials and their assignments in the orange pages by FEMA/NFA, with certain items up for review in 2020 while others will be reviewed before the 2024 version;
      • Distances in the Public Safety section are now in the Evacuation Section;
      • Created a new “How to Use the Orange Guide Pages” section;
      • Guide 121 Gases – inert was merged with Guide 120 Gases – inert (including refrigerated liquids);
      • Added CAUTION sentences for specific materials;
      • Clarify sentences;
      • Address inhalation concerns for petroleum crude oil (UN1267) in Guide 128; and,
      • Reevaluate radioactive materials guides with radiological/nuclear regulatory agencies.

Yellow/Blue Pages [Materials in ID/Name of Material Order]

      • Add or remove UN numbers to align with United Nations Model regulations and North American regulations;
      • Remove UN numbers for chemical warfare agents;
      • Reevaluated guide assignments for some materials; and,
      • Review polymerization hazards for certain materials.

Green Pages [Isolation and Protective Action Distances]

      • Add distances for new Poison Inhalation Hazard/Toxic Inhalation Hazard materials added by regulations;
      • Revise Table 2 introduction;
      • Add container capacities to Table 3;
      • Make a new border to differentiate between Tables 1, 2 and 3; and,
      • Argonne National Laboratory will update the Chemical Accident Statistical Risk Assessment Model (CASRAM) with outcomes from field and lab experiments.

Where Can the Current ERG Be Found?

A free PDF version of the current Emergency Response Guidebook is available online on the PHMSA website. There’s also a mobile app for the guide available for both Android and iPhone devices.    If you’d like to purchase a hard copy for your use, check out the iSi online store.

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Download a pdf copy of these changes that you can share with your team!

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Purchase your copy of the 2020 ERG today from our store! 

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DOT Hazardous Materials Registrations Due July 1

DOT Hazardous Materials Registrations Due July 1

If your company ships or transports hazardous materials, including hazardous waste, you are required to register for a U.S. Department of Transportation (DOT) number. These registrations are due for renewal annually and the payments are due before July 1.

DOT registration fees are based on the nature and size of your company. You will need to know the primary NAICS Code for your company first. There are two tiers of company sizes: “small” and “large” based on number of employees and revenues. Small company fees are $250/year and large company fees are $2,575/year.

You can register by mail or online at https://www.phmsa.dot.gov/registration/online-registration.  Your company cannot transport hazardous materials until registered. If your company has failed to register for any previous years, you will need to register for any missed years and pay for those as well.

DOT has the option for your company to register for up to three years at a time.

If you are transporting hazardous materials, certificates of registration are required to be kept in your vehicle at all times. These will be required during roadside inspections. Failure to have one in the vehicle, or failure to have an updated certificate, could result in a fine of up to $37,500 per day.

In addition, copies of the certificates of registration are to be kept for three years at your place of business and must be available for inspection.

Fees that are collected from DOT registrations are used to pay for grants and state and Indian tribe programs related to hazardous materials emergency response planning and training.

If you need assistance in determining the DOT registration process applies to your company, or need help in completing the paperwork for this requirement, please contact us. Also, if your company is shipping or transporting certain types of hazardous materials or large bulk quantities (6,614 lbs. of solids or 792 gallons of liquid), you are required to have DOT Security Plans in place. iSi can help determine if this additional requirement applies to you, and help you prepare these plans as well. Please contact us for more information.

Need Help?

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iSi can help you with DOT hazmat transportation compliance. Contact us today!

What are Lab Packs and How Could Your Facility Use Them?

What are Lab Packs and How Could Your Facility Use Them?

Casey Moore, iSi Environmental

About the Author: iSi’s Casey Moore has more than 25 years of experience in the hazardous waste industry including working for hazardous waste carriers and operating hazardous waste facilities in California and Arizona.

I’ve never been a fan of “spring” cleaning, but it’s a necessary part of good housekeeping around the home or at your facility. When was the last time your facility did a “spring cleaning” walkthrough to see if there are any materials around your workplace that are expired, or you don’t need?  Flammable cabinets, chemical storage, research/QC labs and maintenance shops are likely places these items accumulate.

What is a Lab Pack?

Since most of the items in these locations are likely to be in smaller containers, they aren’t treated like regular waste streams. Lab packs are a practical solution. Lab packs are consolidation packaging of “like” materials from the smaller containers into larger containers to satisfy proper DOT shipping and EPA RCRA hazardous waste management.

The lab pack was designed for managing expired materials in labs, however, it’s something that can be used for any facility that needs to do a cleanout of smaller containers usually less than 10 gallons each.

What Items Are Candidates for a Lab Pack?

Look for jars, jugs, vials and cans of hazardous materials, including chemicals, solvents, paints, thinners, acids, cleaners, strippers, inks and more. These are typically out of date, off-specification, partially used, and no longer needed.

Who Does Lab Packing?

There are strict regulations about who is qualified to do lab packing. These persons need to determine which containers can be put together and which ones may cause harmful reactions when mixed. Typically, hazardous waste carriers provide this service.

How is Lab Packing Accomplished?

First, items are segregated, that is, sorted, for combining into one larger container.  Items are segregated by:

  • Hazard class — most common are flammables, corrosives, and toxics
  • Type of material — liquids, solids, etc.
  • Compatibility

“Paper pack” is the term used to show the segregation by container. An initial inventory list is converted into lab pack inventory sheets (what goes into each container). This is what waste companies use to create approval numbers for compliance under RCRA. It is also how they establish price. Pricing is based on disposal, transportation and labor associated with packaging.

Packaging is accomplished by:

  • Putting the segregated materials into their respective larger containers;
  • Filling with a packing material (vermiculite is most common) to create stability and containment while shipping;
  • Vermiculite will be in the base and surrounding each of the internal containers; and,
  • The smaller containers are placed into the larger container vertically, so the label with the double arrows pointing up is on the outer packaging.

RCRA Regulation Implications

A lab pack counts towards your waste generation status if you’re a Very Small Quantity Generator (VSQG) or a Small Quantity Generator (SQG), so be mindful of the amount of hazardous waste generated in the process.

For states that have already adopted the Generator Improvements Rule, this is a good use of the episodic event and would not count against your generator status.

If you have any questions regarding lab packs or hazardous waste regulations, contact us!

iSi can help with hazardous waste compliance and facility walkthroughs to find environmental and safety issues.  Contact us today!

The Federal Shutdown: EPA, OSHA and DOT

The Federal Shutdown: EPA, OSHA and DOT

We were working on preparing price proposals for two separate federal agencies this week and one greeted with a return email saying it was closed, while the other is still open.  This prompted the question…what about the other regulatory agencies we work with such as EPA, OSHA and the DOT?

EPA

In short, part of EPA is open while the other is closed.  Those functions still open involve ensuring there are personnel necessary to respond to emergencies involving safety of human life or the protection of property. 

Functions Still Open at EPA

  • Activities essential to ensure safe continued public health and safety including safe use of food and drugs and safe use of hazardous materials;
  • Superfund projects, where failure to maintain operations would pose an imminent threat;
  • EPA labs where it’s necessary to ensure physical integrity of research property and research conditions;
  • Law enforcement, legal counseling and criminal investigations;
  • Protection of federal lands/buildings/equipment; and,
  • Emergency response readiness and disaster service.

Functions Closed at EPA

  • Inspections;*
  • Non-emergency environmental site sampling;
  • New contract obligations;
  • Existing contract obligations and task orders;
  • Existing grant, cooperative agreement and interagency agreement obligations;
  • Payment activities including contracts, grants and payroll;
  • Travel;
  • New hiring; and,
  • Non-mission critical IT systems.

*While federal inspectors are on hold, please note that state environmental inspections are likely to continue using other sources of funding. 

For more information on EPA’s shutdown, take a look at their contingency plan.

OSHA

At OSHA, it is business as usual because their agency is funded through September of this year.   The same goes for MSHA, so inspectors for both agencies are still out and active. 

DOT

At DOT, some agencies of DOT are busier than others are. 

It’s business as usual for the Federal Motor Carrier Safety Administration and the Federal Highway Administration because they’ve already been funded by multi-year appropriations. 

Functions Closed at DOT

At other DOT agencies, about half of the staff has been furloughed.  Much of what is closed has been administrative such as rulemaking and program development, training, research, purchasing, and grants.   

Functions Open at DOT

Those functions still operational include:

  • Hazardous materials (hazmat) inspections of shippers and carriers;
  • Hazmat enforcement activities;
  • Hazmat testing facilities and cylinder reconditioning facilities;
  • Hazmat approvals and permits for emergencies only;
  • Pipeline safety regulation inspectors;
  • Those who manage rail and pipeline accidents/incident investigations; and,
  • Pipeline operations/systems inspectors.

For more information about all the DOT shutdown activities, download their Shutdown Contingency Plan.

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We can help with EPA, OSHA & DOT concerns — Contact us today!

Who Regulates Hazmat Shipments?

Who Regulates Hazmat Shipments?

In the environmental and safety world, it’s pretty simple to determine who’s the regulatory authority. For safety, in most cases it’s OSHA, and if you’re in a “state plan” state or if you’re a public entity, your state has an additional safety regulatory agency. For environmental issues, it’s EPA and for many states there is an additional state agency which covers environmental regulations plus you have municipal environmental rules. However, when it comes to shipping hazardous materials, it gets a little more complicated.

In the U.S., the shipment of hazardous materials is covered by federal regulation 49 CFR. 49 CFR addresses the shipment of hazardous materials by ground, air and vessel. The Department of Transportation (DOT) is responsible for enforcing 49 CFR.

DOT contains a variety of agencies which are responsible for ensuring specific parts of 49 CFR are being followed:

  • Pipeline and Hazardous Materials Security Administration (PHMSA);
  • Federal Aviation Administration (FAA);
  • Federal Motor Carrier Safety Administration (FMCSA); and,
  • Federal Railroad Administration (FRA).

In addition to the federal agencies, there are additional state agencies with the authority to enforce DOT regulations. For example, this could be your state’s department of transportation and additional agencies which govern the highway patrol, rail lines or pipelines. Thus, you could receive inspections from a variety of state officials and highway patrol in additional to the federal agencies.

If there was one arm of DOT which takes the lead in hazardous materials, it’s PHMSA. PHMSA’s focus is safe shipments and it creates and publicizes regulations. Thus, if you wanted to learn new information about shipping hazardous materials, start with PHMSA.

When it comes to air and vessel shipments, you’ll find that although 49 CFR has rules regarding these types of shipments, in parts, 49 CFR defers to two other agencies, the International Air Transport Association (IATA) and the International Maritime Organization who publishes the International Dangerous Goods Code (IMDG). These are international organizations, as the shipment of hazardous materials will often cross country boundaries via ocean or air. Thus, when you’re required to have training, you need the training of both 49 CFR and IATA or IMDG. IMDG can also be applicable to shipments within in the U.S. when shipping to Hawaii, Alaska or Puerto Rico.

Radioactive materials shipments are regulated under the U.S. Nuclear Regulatory Commission (NRC).

Both OSHA and EPA mention and defer to DOT within its regulations. Thus, you need to be aware AND trained in both the regulations of OSHA/EPA and DOT when dealing with environmental or safety issues.

49 CFR regulations can become very confusing. If you need help determining which regulations apply to you and how you need to ship your hazardous materials, contact us and we’d be happy to help!

Need Help?

Need help sorting out your hazmat shipping requirements? What about your required training?

iSi can help you with hazmat shipping regulations — Contact us today!

Hazardous Waste e-Manifest System Coming in June

Hazardous Waste e-Manifest System Coming in June

EPA is establishing a nationwide electronic hazardous waste tracking system, and it hopes to have it up and running by June. The system will be known as e-Manifest, and will allow shippers to complete electronic manifests and destination/receiving facilities the opportunity to electronically upload manifests.

All states will be required to implement e-Manifest and incorporate it into their hazardous waste programs as an option. The system will be linked to RCRAInfo, a separate site which collects information on hazardous waste sites.

Right now, the using e-Manifest will be optional. Paper manifests will still be accepted from generators for the foreseeable future, and from destination/receiving facilities for up to three years. EPA hopes that by using electronic means, significant gains in cost, time, accuracy, notification, and monitoring effectiveness can be realized by all who use the system. Electronic manifests will be just as legal as paper ones, except they’ll be completed and signed electronically.

Using e-Manifest will satisfy EPA, RCRA and DOT 3-year recordkeeping requirements. EPA is also working with DOT to ensure e-Manifest will produce a proper shipping paper. DOT will still be requiring hard copies to be sent with the shipment, so those using e-Manifest will be able to print out a copy of their manifest for DOT purposes.

In the future, the e-Manifest system may link to the Biennial Hazardous Waste Report, and potentially replace it.

The fees for the system will be paid by the destination or receiving facility, which more than likely will be passed down to the generator. Fees will be per manifest, and fees for electronic manifests will be lower than the paper ones.

The target date for e-Manifest roll-out is June 30, 2018.

Need Help?

Need guidance or support with hazardous waste? Do you have your required training and reporting complete?

Need Help?

Need guidance or support with hazardous waste? Do you have your required training and reporting complete?

EPA is establishing a nationwide electronic hazardous waste tracking system, and it hopes to have it up and running by June. The system will be known as e-Manifest, and will allow shippers to complete electronic manifests and destination/receiving facilities the opportunity to electronically upload manifests.

All states will be required to implement e-Manifest and incorporate it into their hazardous waste programs as an option. The system will be linked to RCRAInfo, a separate site which collects information on hazardous waste sites.

Right now, the using e-Manifest will be optional. Paper manifests will still be accepted from generators for the foreseeable future, and from destination/receiving facilities for up to three years. EPA hopes that by using electronic means, significant gains in cost, time, accuracy, notification, and monitoring effectiveness can be realized by all who use the system. Electronic manifests will be just as legal as paper ones, except they’ll be completed and signed electronically.

Using e-Manifest will satisfy EPA, RCRA and DOT 3-year recordkeeping requirements. EPA is also working with DOT to ensure e-Manifest will produce a proper shipping paper. DOT will still be requiring hard copies to be sent with the shipment, so those using e-Manifest will be able to print out a copy of their manifest for DOT purposes.

In the future, the e-Manifest system may link to the Biennial Hazardous Waste Report, and potentially replace it.

The fees for the system will be paid by the destination or receiving facility, which more than likely will be passed down to the generator. Fees will be per manifest, and fees for electronic manifests will be lower than the paper ones.

The target date for e-Manifest roll-out is June 30, 2018.

iSi can help you with hazardous waste compliance — Contact us today!

Hazardous Waste Manifest Signers Need DOT Training

Hazardous Waste Manifest Signers Need DOT Training

Did you know anyone who signs a haz waste manifest on behalf of your company is required to have DOT training?

We come across many companies who have overlooked this important requirement, especially if their haz waste transporter is filling out all the paperwork for them.  Your hazardous waste is covered under EPA regulations, but once it’s sent for transportation, it becomes a hazardous material and is subject to DOT regulations.

Under DOT, your company is the shipper, not the hazardous waste transporter.  Even if the person signing the manifest doesn’t complete any of the shipping paperwork, (that is, if the transporter prepares it), as soon as he or she signs it, they become legally responsible for that shipment.  With their signature, they’re certifying everything has been packaged correctly, labeled correctly and that the forms have been filled out correctly.  Per DOT, this cannot occur without proper training.

Thus, in addition to hazardous waste training, the person signing your manifest needs DOT training.  This requirement can be satisfied through our Ground Hazardous Materials (DOT) Transportation course.  Visit our training page for dates, times and pricing.

iSi can help your company with haz waste and DOT compliance! Check us out!

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