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Jim Fox | Hazardous Materials Specialist 2018

HHW and VSQG Annual Update – DOT Hazardous Materials Compliance MPCA 2018 Household Hazardous Waste Training. Jim Fox | Hazardous Materials Specialist 2018. Transportation in Commerce. Transportation in Commerce.

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Jim Fox | Hazardous Materials Specialist 2018

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  1. HHW and VSQG Annual Update –DOT Hazardous Materials ComplianceMPCA 2018 Household Hazardous Waste Training Jim Fox | Hazardous Materials Specialist 2018

  2. Transportation in Commerce

  3. Transportation in Commerce • Movement of HHW to a collection site is not regulated by the HMR (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 • USDOT hazardous materials regulations apply to shippers/offerors (including government agencies) who offer hazmat for transportation in commerce • Commercial carrier may not accept the hazmat unless it is packaged and documented as required in the HMR

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

  6. 2018 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 New 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-215L Harmonization With International Standards Minimum size requirements for ID number markings (with certain exceptions) on non-bulk packages under 49 CFR 172.301(a). Mandatory compliance was 1/1/17.

  11. 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.

  12. HM-215N Harmonization With International Standards • Amended HMR By: • 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:

  13. 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. • Incorporated By Reference Date: 3/30/17

  14. Guidance On Display Of GHS Labels On BULK Packages • The Commercial Vehicle Safety Alliance recently 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.

  15. What’s On The Horizon? • HM-215O Harmonization With International Standards • HM-219C Adoption Of Miscellaneous Petitions To Reduce Regulatory Burdens • HM-233G Continued Conversion of Special Permits

  16. QUESTIONS?

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

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

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

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