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Some common issues regarding the use and transportation of hazardous materials
are listed below. The list is intended to be a starting point for understanding
common regulatory issues rather than a definitive list of everything needed
to be in compliance. User/Transporters are urged to consult the appropriate
regulatory agency for questions regarding their specific situations.
The Federal DOT regulated the transportation of hazardous
materials in the US. Complete DOT regulations can be found in Volume 49
of the Code of Federal Regulations. The Code of Federal Regulations is
available from any government bookstore or library serving as a Federal
Repository. The DOT code can also be found on line at www.hazmat.dot.gov
At this website, clicking on a diamond will take you to the corresponding
regulations. For example, the diamond labeled "Security" will
take you to the regulations regarding Security, including who must comply
and what steps must be taken to comply.
Some of the more common DOT regulations are described below. Note that
these descriptions generally apply to domestic ground shipments. Air and
international shipments may have slightly different requirements. Air
shipments are generally regulated by the IATA (International Air Transport
Association) and international shipments are generally governed by international
IMF (intermodal freight) regulations.
Hazardous Materials
Any material listed in the table of hazardous materials (49CFR172.101)
or by definition in the section preceding the table. For example, anything
flammable or under pressure. The hazardous materials table will also describe
the proper shipping name for the material, the class, packaging group
and approved containers.
Training
Required for employees who handle, prepare for shipment or ship hazardous
materials. Specific requirements are found at 49CFR171.700
Shipping Papers
Shipments of hazardous materials by common carriers require accompanying
paperwork showing the shipment contains hazardous materials, the quantity,
proper shipping name, hazard class, packaging group, emergency contact
number and a certification that the shipment has been prepared in accordance
with DOT regulations. Specific requirements are listed in 49CFR172.200
Placarding
Placarding of the truck with the appropriate warning placard is required
for hazardous materials shipments exceeding 1,000lbs gross weight. It
is the shippers responsibility to provide the placards to the carrier
to place on the truck. If two hazard classes are shipped together (eg,
a flammable liquid class 3 and a flammable gas glass 2) a “Dangerous”
placard can be used instead of two separate placards as long as less than
5,000lbs gross weight of any hazard class is shipped. Individual placards
must be used when shipping greater than 5,000lbs gross weight for any
hazard class. Specific placarding requirements, including a description
of the placards can be found at 49CFR172.500 Placards are commonly available
from many sources including McMaster Carr.
Registration
Registration with the DOT is required for shipping amounts requiring placarding,
and for certain other requirements. Registration requirements can be found
at 49CFR.107.601
Security
Security, including a written plan and documented employee training is
required for shippers of hazardous materials. HAZMAT security requirements
can be found at 49CFR172.800. Shipping amounts requiring placarding would
trigger the security requirement.
Emergency Response Number
Hazardours materials offered for transport also require a 34 hr emergency
response number on the accompanying shipping papers. Specific requirements
can be found at 49CFR172.604
OSHA generally regulates health and safety in the worklplace.
Specific standards can be found in Volume 29 of the Code of Federal Regulations
or by going to www.osha.gov
and clicking on “standards”.
The most common OSHA standard is the Hazard Communication Standard, which
can be found in 29CFR1910.1200. This standard applies to workers using
hazardous materials in the workplace and describes training and MSDS requirements.
The HCS applies to manufacturers, importers, and distributors of hazardous
chemicals.
OSHA also has specific standards for certain workplace hazards, including
use of electrical equipment, standards for exposure to certain chemicals,
scaffolding, use of forklifts, and so forth. Employers should consult
the OSHA standard for any that may specifically apply to their workplace.
Note the OSHA only covers worker safety and exposure in the workplace.
Northstar products are sold for industrial use and would be governed in
the workplace by these requirements. Products sold to consumers (i.e.,
the general public) are governed by the Consumer Product Safety Commission.
These safety requirements can be different from general OSHA requirements
and are found in Volume 16 of the Code of Federal Regulations, Consumer
Product Safety. Anyone selling direct to consumers should consult these
regulations.
The EPA regulates the quality of the air, water, and land, including the
release and disposal of hazardous materials. Specific EPA regulations
can be found at www.epa.gov
by clicking on a particular topic, such as “air”.
Most states have implementation plans approved by the EPA that regulate
air, water, and ground quality within their borders. State plans can be
more restrictive than the EPA but can not be looser. Therefore, users
of hazardous chemicals should consult their specific state plans for any
regulations that might apply.
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