NITRATE FILM

1. AMIA 2005, Austin NITRATE FILM TRANSPORTATION REGULATIONS Rosa Gaiarsa Collection Services Manager UCLA Film & Television Archive

2. First transportation guidelines • First version of Recommendations on the Transport of Dangerous Goods, RTDG, published in 1956 by the UN United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods http://www.unece.org/trans/danger/publi/unrec/rev14/14files_e.html

3. UN Recommendations (RTDG) • The document is regularly amended to align with new technologies and changing needs of users • The document itself has no legal force except when adopted in agreements and/or domestic legislation

4. US - Regulatory history 1975 –Transportation Safety Act • Established the National Transportation Safety Board as an independent agency and authorized the Secretary to…regulate the transportation of all hazardous materials, and to impose both civil and criminal penalties for violations of those regulations

5. US - Regulatory evolution • 1977 – Transportation Safety Institute and other agencies are consolidated into the Research and Special Programs Administration, RSPA • 2004 – RSPA reorganizedinto Pipeline and Hazardous Materials Safety Administration, PHMSA http://hazmat.dot.gov/

6. US - Regulatory Code All modes of transportation of dangerous goods are regulated by the Department of Transportation’s Code of Federal Regulations,CFR49 http://www.myregs.com/dotrspa

7. Four Modal Regulations • Highway • Rail • Water • Air

8. Internationalregulations - Air • ICAO: International Civil Aviation Organization’s Standards and Recommended Practices – Technical Instructions for the Safe Transport of Dangerous Goods by Air http://www.icao.int • IATA: International Air Transport Association’s Dangerous Goods Regulations (more restrictive than ICAO – updated annually) http://www.iata.org

9. Basic shipment requirements • Classification • Identification • Packaging • Marking and labeling • Documentation • Training

11. Classification – UN criteria • Class 1 – Explosives • Class 2 – Gases • Class 3 – Flammable liquids • Class 4 – Flammable solids • Class 5 – Oxidizing Substances • Class 6 – Toxic and infectious substances • Class 7 – Radioactive material • Class 8 – Corrosives • Class 9 – Miscellaneous DG

12. Class 4 subdivision • 4.1 Flammable solids • 4.2 Substances liable to spontaneous combustion • 4.3 Substances which, in contact with water, emit flammable gases (dangerous when wet)

13. Identification / Packing group • Proper shipping name Films, nitrocellulose base • UN / ID UN1324 • Packing group • Group I (X): high danger • Group II (Y): medium danger (IATA) • Group III (Z): low danger (CFR)

14. UN certified outer package Example: Fiberboard box UN 4G Buyers beware: request copy of test report from manufacturer and/or supplier of packaging materials

15. Packaging types • Inner package: film can or box • Outer package: list of fourteen containers that are tested and certified by UN specifications • Overpack: to bundle outer packages for shipment

16. Packing instructions IATA • Y400 • Limited quantities: • 1 kg per inner package • 10 kg (22 lbs) net weight • 400 • Passenger and cargo aircraft: • 25 kg (55 lbs) • Cargo aircraft only: • 100 kg (220 lbs)

17. Marking and labeling • Shipment label: shipper and consignee info • Hazard label • Proper shipping name • UN/ID number • Multiple packages ID mark on overpack • Net quantity info in kg • Overpack notice • Air eligibility label

18. Placarding – CFR49 • Vehicles transporting more than 1001 lbs (454 kg) of nitrate film have to be placarded • It’s the responsibility of the shipper to provide the proper placards to the carrier • If you offer for shipment an amount of nitrate film that requires placarding, registration with the DOT is required

19. Documentation Shipper’s Declaration of Dangerous Goods • Two copies required by law, but some carriers require three copies • Papers have to be retained for 375 days after the material is accepted by the initial carrier

20. Emergency telephone number A person who offers a hazardous material for transportation must provide an emergency response telephone number, including the area code or international access code, for use in the event of an emergency involving the hazardous material

21. Emergency phone / requirements • Person must be knowledgeable of the hazardous material being shipped • Person must have comprehensive emergency response and incident mitigation information for the material • Phone must be monitored at all times, 24/7 • Answering service, answering machine, or beeper devices are not accepted

22. Emergency phone / options • The telephone number must be the number of the person offering the hazardous material for transportation or • The number of an agency or organization capable and responsible for providing detailed information concerning the hazardous material

23. Emergency phone / service providers • US • Chemtrec • Chem-tel • Infotrac • 3E Company • Canada • Canutec http://hazmat.dot.gov/pubs/erg/erg2004.pdf

24. Hazmat Training • Employer is responsible for compliance with training requirements • Training may be provided by the employer or other public or private sources • Employee has to be trained within 90 days of employment • Employee has to be re-trained every 24 months (IATA)

25. Training content • General awareness • Function-specific training • Safety training • Awareness training of transportation security risk (CFR, added in 2003) • In-depth training of security plan (CFR, added in 2003)

26. Testing and documentation • After training, Hazmat employee has to be tested and provided with a certificate of training completion • Training records have to be kept and made available to enforcement agents upon demand http://hazmat.dot.gov/training/training.htm

27. CFR49 / Materials of trade exception Material of trade means a hazardous material other than hazardous waste that is… -- carried by a private motor carrier in direct support of a principal business (that is not transportation)

28. Materials of trade regulations • Less restrictive packaging • Less restrictive marking and labeling • Limit of 30 kg (66 lbs) per package • Aggregate gross weight may not exceed 200 kg (440 lbs)

29. Better safe than sorry • Any violation of a requirement of the Federal hazardous material transportation law is liable for a civil penalty of not more than $32,500 and not less than $275 for each violation • Federal law forbids the carriage of hazardous materials aboard aircraft in your luggage or on your person. A violation can result in five years' imprisonment and penalties of $250,000 or more

30. AMIA 2005, Austin NITRATE FILM DISPOSAL REGULATIONS Rosa Gaiarsa Collection Services Manager UCLA Film & Television Archive

31. US - Regulatory history • 1965 – Solid Waste Disposal Act wassigned • 1970 – Environmental Protection Agency was created • 1976 – Resource Conservation and Recovery Act was signed http://www.epa.gov/epaoswer/general/k02027.pdf

32. US – Regulatory code 1980: RCRA published the Hazardous Waste and Consolidated Permit Regulations • Tracking and permitting to monitor and control hazardous waste • Strict requirements for storage, treatment and disposal of hazardous waste • Authorized States to implement RCRA’s waste management program

33. Regulatory amendment • Regulated businesses that generated even small amounts of hazardous waste 1984 - Hazardous and Solid Waste Amendments http://www.epa.gov/epaoswer/general/orientat/romtoc.pdf

34. Hazardous Waste identification • Listed • Characteristics • Ignitable • Corrosive • Reactive • Toxic

35. Waste generator classifications • Large quantity generator (LQG) • 1000 kg (2200 lbs) or more of hazardous waste per month • Small quantity generator (SQG) • More than 100 kg (220 lbs) but less than 1000 kg per month • Conditionally exempt small quantity generator (CESQG) • Less than 100 kg (+/- 45x1000ft cans) per month

36. State regulations* • State regulations may be more strict than Federal requirements • Some States require CESQGs to follow some of the SQGs requirements * Generators need to contact their respective state agency to determine if state regulation differs from federal requirements

37. Requirements for SQGs • Obtain an EPA identification number from your State Environmental Office • Comply with accumulation and storage requirements • Comply with requirements for training, contingency planning and emergency response • Prepare the waste for shipment (packaging, labeling, marking, placarding) • Comply with the manifest system • Meet record keeping and reporting requirements

38. Accumulation and storage requirements • CESQGs cannot accumulate more than 1,000 kg (2200 lbs = +/- 450 x 1000ft cans) of hazardous waste on site at any time • SQGs can accumulate no more than 6,000 kg (13,228 lbs) on site for up to 180 days without a permit http://www.epa.gov/epaoswer/hazwaste/sqg/handbook/k01005.pdf

39. Preparation for shipment – 49CFR • Proper shipping name: Nitrocellulose with water(with no less than 25% water, by mass) • UN/ID: UN 2555 • Hazard label: 4.1 • Packing group: II • Packing instructions: • Limited quantities: 173.151 • Non-bulk: 173.212

40. Selecting Transporter and TSDF • Your institution’s Hazmat Office • Local references • Trade associations • Better Business Bureau • City, County or State Hazmat Management Agency • Regional EPA Office (Treatment, Storage and Disposal Facility)

41. Manifest* • Required by EPA and DOT • Multiple copies as tracking tool from generator to transporter to disposal facility • Records retained for three years * new form to be adopted in 2006

42. Enforcement • EPA can use administrative, civil, or criminal enforcement actions to address RCRA violations • Penalty amounts are case specific • Penalty is calculated on base amount and a multi-day component • EPA may reduce or waive penalties for violations that are promptly disclosed and corrected

43. EPA contact information http://www.epa.gov/epaoswer/osw/comments.htm Links to State web pages and EPA regional web pages