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Jim Fox | Hazardous Materials Specialist 2019

This annual update covers key changes to the DOT Hazardous Materials Regulations relevant to household hazardous waste and transportation in commerce. Learn about ORM-D, Lithium batteries, and international standards harmonization. Stay compliant with HM-215K, HM-215M, HM-215N, and HM-219A.

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Jim Fox | Hazardous Materials Specialist 2019

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  1. HHW and VSQG Annual Update –DOT Hazardous Materials ComplianceMPCA 2019 Household Hazardous Waste Training Jim Fox | Hazardous Materials Specialist 2019

  2. Transportation in Commerce

  3. Transportation in Commerce • Movement of HHW to a collection site is not regulated by the Hazardous Materials Regulations (HMR) See 173.12(g). • Movement by a VSQG to a collection site is regulated-Remember though, they may use exceptions (i.e. Materials of Trade.) • Shipping or offering waste from HHW/VSQG consolidation site to commercial transporter is fully regulated by the HMR

  4. Offering the ShipmentCollection Site to Commercial Transporter • The USDOT HMRs apply to shippers/offerors (including government agencies) who offer hazmat (HM) for transportation in commerce • Commercial carrier may not accept the HM unless it is packaged and documented as required in the HMR

  5. Remember the BasicsUSDOT Regulated Activities • Classifying the material: Hazard class, subsidiary hazards, packing group, haz substance, haz waste • Creating the Shipping Paper: Basic Description and Other DOT required information • Selecting correct packaging: Packagings must be “authorized” by the HMR • Preparing the packages: Properly filled, closed, and in condition for transport

  6. 2019 Annual Updates • Changes To The HMR Pertinent To HHW And VSQG Programs

  7. HM-215K Continued Use Of ORM-D Classification • On 1/1/13, the use of the “ORM-D” classification system, and markings, were no longer authorized for use by any mode, except highway (until 12/31/20) and was replaced by Limited Quantity (LTD QTY.)

  8. “OLD” ORM-D Marking Example

  9. Air - but can be used by other modes. 172.315- Limited Quantity Marking Package containing LTD QTY does NOT need to be marked with PSN and ID# if marked with these new limited quantity white square on point marking. Technical names, RQ, etc still required in association with the marking, if by air. ORM-D markings can be used until 12/31/2020 for highway

  10. HM-215M Harmonization With International Standards • Certain package and overpack marks and labels conforming to regulations in effect on 12/31/14 were no longer allowed beginning on 12/31/16. EXCEPT, that for domestic transportation, a packaging or overpack marked prior to 1/1/17 and in conformance with the requirements in effect on 12/31/14, may continue in service until the end of its useful life.

  11. HM-215M Continued • Compliance with new specifications for label inner borders (size and distance) is required on 1/1/19 (previous date was 1/1/17)

  12. HM-215N Harmonization With International Standards • Incorporations By Reference; ICAO Technical Instructions, IMDG Code, UN Modal Regulations, 6th Edition of the GHS, and Canadian TDG. • HM Table: Added, revised or removed certain proper shipping names, hazard classes, packing groups, special provisions and packaging authorizations. • Provisions for Polymerizing Substances: Included in the HMT four new Division 4.1 entries for polymerizing substances, and added defining criteria, authorized packagings, and safety requirements. • Hazard Communication Requirements For Lithium Batteries: New marking (see 173.185(c)) and new label (see 172.447(c) and Special Provision 422.

  13. HM-215N Continued-New Lithium Battery marking and label

  14. HM-215N Continued • Effective Date: 3/30/17 • Voluntary Compliance Date: 1/1/17 • Delayed Compliance Date: Unless otherwise specified, compliance required 1/1/18. ***1/1/19 for lithium battery communications.*** • Incorporated By Reference Date: 3/30/17

  15. HM-215O-(Proposed) More Harmonization With International Standards • Incorporation by Reference of; ICAO, IMDG Code, and UN Model Regulations (6th Edition of the Manual of Tests and Criteria, and 7th Edition of the Globally Harmonized System of Classification.) • Changes to the HM Table • Lithium batteries • Alternative criteria for classification of corrosive materials (Class 8) • Provisions for polymerizing substance • Comments due by 1/28/19

  16. HM-219A Response To Industry Petitions • Amends the HMR to update, clarify, streamline or provide relief from miscellaneous regulatory requirements • Incorporates by reference multiple publications from the Compressed Gas Institute, the Chlorine Institute, and the Department of Defense. • Allows combination non-bulk packagings that are tested and marked for liquid HM to be used for solid HM. • Allows electronic signatures for EPA UHWMs

  17. HM-219A Continued • Effective Date: 12/7/18 • Voluntary Compliance Date: 11/7/18 • Delayed Compliance Date: Unless otherwise specified, compliance required by 11/7/19. • Incorporated By Reference Date: 12/7/18

  18. Guidance On Display Of GHS Labels On BULK Packages • The Commercial Vehicle Safety Alliance (CVSA) issued an Inspection Bulletin, # 2017-03 – “Display Of GHS Labels On Bulk Packages” (dated 9/21/17.) In addition, on 9/19/16, PHMSA and OSHA issued a Joint Guidance Memorandum - “Labeling of Hazardous Chemicals for Bulk Shipments.” • The display of a marking or label not required by the HMR, but conforming to OSHA’s HCS 2012 and consistent with the GHS, is NOT a violation of the HMR. • However, a GHS pictogram or label displayed on a bulk package that does not constitute a complete GHS label (e.g. a pictogram alone or required label elements missing) WOULD constitute a violation of the HMR.

  19. EPA’s e-Manifest • New system designed to save money/increase efficiency • When completely implemented, totally electronic, including signatures • Paper manifests allowed until 6/30/23 • US DOT still requires a paper copy to be carried with the shipment to comply with their shipping paper requirement.

  20. What’s On The Horizon? Things to Watch • HM-215O Harmonization With International Standards-NPRM (comments by 1/28/19) • HM-233G Continued Conversion of Special Permits • EPA Reclassification of Aerosols to Universal Waste • EPA IFR Exempting Airbag Waste from Hazardous Waste rules

  21. QUESTIONS?

  22. ???????????USDOT HazMat Hotline (800) 467-4922 Or http://hazmat.dot.gov

  23. Check Out Our Web-Based HazMat Training!! www.dot.state.mn.us/cvo/hazmatElearning/

  24. Thank you! Jim Fox jim.fox@state.mn.us 651-366-4348

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