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DOT Hazardous Material Regulations (49 CFR 100-179)
Purpose: The purpose of the DOT hazardous material regulations (HMR) are to promote the safe transportation of hazardous material through the effective communication of information concerning the hazards of hazardous materials being transported. Through the communication of this information, accidents are either altogether avoided or, emergency responders are properly prepared to respond to a given incident or accident.
Overview
The requirements
of HMR
| Marking | ||
| Placarding | ||
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Employee Training | |
Hazardous Material Classification
Do any of the following pertain to your product in question?
| Product Hazards | Yes | No |
| Poisonous by inhalation - Liquid | ||
| Flammable Liquid - PG I (Flash point <73F, BP<=95F) | ||
| Flammable Liquid - PG II (Flash point <73F, BP>95F) | ||
| Flammable Liquid - PG III (Flash point >=73F<=141F, BP>95F) | ||
| Corrosive - PG I (Full destruction of skin after 3 min. exposure, observed 60 min.) | ||
| Corrosive - PG I I(Full destruction of skin after 3 -60 min. exposure, observed after 14 days) | ||
| Corrosive - PG III (Full destruction of skin after >60 min. exposure, observed after 14 days) | ||
| Flammable Solid | ||
| Spontaneously Combustible | ||
| Oxidizer | ||
| Combustible Liquid (Flash point >141 F < 200 F) | ||
| Poisonous other than by inhalation |
Are any of the above categories checked Yes? ______ If no, material is not DOT Hazardous.
Are any of the above categories checked Yes? _________ If yes, material is DOT Hazardous.
If more than one Hazard checked yes, hazard precedence table needs to be consulted to determine primary and subsidiary hazards.
Primary hazard: ____________________________
Subsidiary Hazard: ____________________________
Shipping papers of DOT Hazardous materials must contain the following:
Proper shipping Name as listed in Hazardous Material Table. If a material is described on the HMT with a “n.o.s.” description, the technical name of the hazardous component must be entered in association with the basic description. Hazard Class (not required for combustibles) Identification number (UN or NA) Packing group, in roman numerals Total quantity including the unit of measurement
Shippers Certification:
Each person who offers a hazardous material for transportation shall certify that the material is offered for transportation in accordance with the regulations by including a shippers certification statement on the shipping papers. This statement might read:
“I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packed, marked, labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations”
Hazardous and Non Hazardous Materials:
When hazardous and non-hazardous materials are described on the same shipping paper, the hazardous material entries must be:
Entered First or Printed in a contrasting color or highlighted or Identified by the entry of an “X” placed before the PSN in a column captioned “HM”
Accessibility of Shipping Papers:
For those of you running your own trucks, the shipping papers must be readily accessible. Specifically they must be within the drivers immediate reach when he is at the wheel. This may be a holder on the door, or on the seat next to the driver. When the driver is not at the wheel, the papers must be in a holder on the drivers door or on the drivers seat. All hazardous shipping papers must appear first or be distinctively tabbed. Trucks must also be equipped with Emergency Response Information. A copy of the North American Emergency response Guide located with the shipping papers is adequate for compliance.
Emergency Response Telephone Number:
Any person who ships a hazardous material must provide a 24 hour emergency response telephone number for use in the event of an emergency. The phone number must be listed on the shipping papers. The telephone number must provide uninterrupted access to emergency information. Beepers or answering services are not adequate for compliance.
To distinguish between marking & labeling, you can think of marking as language and labeling as placarding for containers. Most services you buy labels from, also contain the marking language. Markings include the proper shipping name, ID number, technical names, up arrows on liquid packages.
Labeling:
All hazardous materials which meet one or more hazard class definition must be labeled as specified in the HMT. Packaging containing a hazardous material that meets the definition of more than one hazard are required to be labeled for multiple hazards. Subsidiary labels for additional hazards may not display the hazard class number. Only the primary hazard label may display this number. If hazardous materials of different hazard classes are packed within the same box, the box must be labeled as if each hazard was a primary hazard (i.e. each label should bear the hazard class number).
Exceptions to labeling: Consumer commodities Limited Quantities of hazardous materials Combustible liquids in non-bulk containers.
Consumer commodities (ORM-D) are a “material that is packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use.” The consumer commodity designation is valid for domestic shipments only.
Limited Quantity exception is valid if designated in column 8A of the HMT for the material in question. Marking and shipping paper requirements are still applicable.
Combustible liquids in non-bulk containers are exempt from DOT regulations.
Placarding requirements apply to each person who offers for transportation or who transports a hazardous material. Each shipper should tender proper placards to common carrier unless declined. Placards must be displayed on each end and side or motor vehicle. Keep in mind that placarding is a fluid process in that the placards required may change as you make deliveries or pick-ups.
Placards are required when aggregate gross weight is 1001 pounds or more of one or more classes of hazardous material. Placards may be required for any weight of explosives, poisonous gases or radioactive materials. When two or more classes of hazardous materials which require different placards are loaded into the same vehicle, and their aggregate weight is greater than 1001 pounds a DANGEROUS placard may be used instead of separate Placarding. However when 2205 pounds or more of hazardous material in a single hazard class is loaded on the vehicle, a placard representing that hazard must be displayed.
Effective Oct. ‘97, no extraneous information (i.e. drive safely) may be on placards, in placard holders or on placard type displays.
Large quantities of Hazardous materials in non bulk packages: A transport containing 8820 pounds or more aggregate gross weight of a hazardous material having a single ID number must be marked on the outside of the vehicle with the ID number. The ID number must be displayed on orange panels or placards. Their are specific requirements for these placards, so further investigation would be necessary should you experience this situation.
Exceptions to placarding: Hazardous materials classified as ORM-D Hazardous material transported as Limited Quantity Combustible liquids in non-bulk packaging Infectious substances.
Segregation of Hazardous Materials
In general, hazardous materials may not be loaded, transported or stored together unless done in accordance with the “segregation table for Hazardous Materials”. These requirements apply to all packages that must be labeled under HMR. If a package is required to bear a subsidiary hazard label, the segregation requirements set forth in the table appropriate to the subsidiary hazard must be applied when that segregation requirement is more restrictive than that required for the primary hazard class.
Performance oriented packaging must be used when transporting hazardous materials. These requirements are based on the United Nations (UN) recommendations on the transport of dangerous goods. Effective Oct. 1, 1996 shippers of hazardous materials must use packaging manufactured in accordance with these standards. Each package must be stamped with a UN designation which certifies that the manufacturer meets the performance oriented packaging standards. You should contact your packaging manufacturer for details on the standards.
Packaging ID Codes:
Example: UN 1A1/Y1.4/150/83/USA/XYZ
1A1: Type of packaging. 1=Drum A=Steel 1=Non removable head drum
Y Packing Group Designation X = PG I, II, III Y = PG II, III Z= PG III
1.4 Gross mass or Specific Gravity. Max specific gravity of product which can be carried by package
150 Hydrostatic Test Pressure. S = combination packaging # = kilopascals test pressure rating
83/USA/XYZ Year of Mfg/Country of Mfg/Mfg individual ID code
Selection of proper packaging:
Classify Hazardous material by hazard class, PG, subsidiary hazards. The classification process may require you to test the material to determine this information. Your supplier may also have this information available. Determine proper shipping name (PSN) by referencing HMT Check column 8 of HMT for DOT authorized packaging. Check column 7 for any limitations which may affect the shipment. Find a packaging which is suitable for the hazardous material being considered: Specific gravity of material PG of material Mode of Shipment Gross mass of packaging plus contents Chemical compatibility of material and package
Employee training is designed to increase an employee’s awareness of safety considerations involved in transportation of hazardous materials, thereby helping to reduce the number of incidents and mitigate their effect.
Who has to be trained:
Any person, who in the course of employment directly affects hazardous material transportation safety including personnel who: (1) Load/unload hazardous materials. (2) Prepare hazardous materials for transportation, including preparing bills of lading. (3) Is responsible for the safety of transporting hazardous materials or (4) Operates a vehicle used to transport hazardous materials.
How often do they need to be trained:
Training shall be complete within 90 days after employment. Recurrent training shall be given at least once every three years or whenever a new regulation is adopted/changed. A record of training and proof of test results shall be retained by each hazmat employer for each hazmat employee for as long as the employee is employed and for 90 days thereafter. All hazmat employees must receive general awareness training and any function specific training.
Materials of Trade
Some interesting situations arose when the HMR went into effect. All of a sudden, salesmen could no longer transport samples and truck drivers couldn’t have a can of bug repellent on board without having the proper paperwork and hazmat compliance. Thus an exception for “materials of trade” was created. MOT is defined as hazardous material that is carried on board a motor vehicle:
(1) in direct support of a principal business that is other than the transportation by motor vehicle. (examples: sales personnel, building service contractors, lawn care, welding, pool care, etc.)
(2) hazardous material on board a motor vehicle for the purpose of protecting the health and safety of the operator. (example: insect repellent).
(3) hazardous material on board a motor vehicle for the purpose of supporting the health and safety of the operator of a motor vehicle including its auxiliary equipment (example: spare battery).
MOT’s are subject to size limitations for individual containers. (1) 8 gallons for PG II & III or ORM-D materials. (2) 400 gallons for a diluted mixture not to exceed 2% of a class 9 material. (3) Aggregate gross weight cannot exceed 440 pounds.
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