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DOT Hazardous Materials Transportation Presented by: Environmental Technical Group, Inc.

DOT Hazardous Materials Transportation Presented by: Environmental Technical Group, Inc. www.etgonline.com. U.S. Department of Transportation. Pipeline and Hazardous Materials Safety Administration, PHMSA (used to be RSPA, Research and Special Programs Administration).

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DOT Hazardous Materials Transportation Presented by: Environmental Technical Group, Inc.

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  1. DOT Hazardous Materials TransportationPresented by:Environmental Technical Group, Inc. www.etgonline.com

  2. U.S. Department of Transportation • Pipeline and Hazardous Materials Safety Administration, PHMSA (used to be RSPA, Research and Special Programs Administration). • Regulates the transportation of hazardous materials.

  3. Hazardous Materials • More than 4 billion tons are transported annually in the U.S. • More than 800,000 shipments occur every day. • Commerce contributes more than $446 billion to U.S. economy. • Important part of everyone’s daily life.

  4. Hazardous Materials - Definition • A material that has the potential to cause an unreasonable risk to health, safety or property when transported in commerce. • 9 Hazard Classes

  5. Hazardous Material Worker A hazardous material worker is one who: • Operates a vehicle transporting hazardous materials. • Loads or unloads hazardous materials; • Prepares hazardous materials for transport; • Prepares shipping documents for the transportation of hazardous materials; or, • Takes responsibility for hazardous material transportation safety.

  6. Hazardous Materials Regulations • Classification • Packaging • Hazard Communication • Emergency Response Information • Training of HazMat employees • Transportation • Incident Reporting • Security

  7. Employer Responsibilities Training must be provided: • within 90 days of hire • renewed every 3 years thereafter. If an employee was previously trained prior to hire, the training must be current (within the last three years).

  8. Manual pg. 1 Employer Responsibilities Required training includes: General Awareness/Familiarization Function Specific Training Safety Training Modal Specific Training Security Awareness Training

  9. Employer Training Violations An employer’s failure to train any Hazardous Materials employee carries potential fines from $1,500 to $25,000. Fines for failure to maintain training records are $500 and up.

  10. Employee Responsibilities • Each employee must ensure each step is complete for the safe transportation of hazardous materials and waste. • Improperly prepared shipments or incomplete paperwork CANNOT be accepted. • If a problem exists, contact a supervisor immediately to describe the situation and receive further instruction.

  11. Transportation Violations and Penalties • Prosecutor only needs to show that an individual had actual knowledge of the violation or prove that the person acting in the circumstances and exercising due care would have such knowledge.

  12. U.S. DOT’s Enforcement Actions Calendar Year 2007 • 169 hazardous materials civil penalty cases • Collected $893,133.04 in penalties

  13. Recent Violations Firmenich, Inc. d/b/a Noville, Inc. South Plainfield, NJ (Shipper) Failed to provide recurrent general awareness and function-specific training and initial security awareness training; and other infractions of the HMR. [172.802(a), 172.704(a)(4), 172.704(c)(2), 172.800(b), 172.702(a)] Penalty: $6,075

  14. Recent Violations Specialty Foundry Products, Inc. Birmingham, AL (Shipper) Failed to register with PHMSA; failed to provide general awareness, function-specific, safety, and security awareness training; offered combustible liquid, n.o.s. (petroleum or petroleum naphthal) 3, accompanied by a shipping paper that included an unauthorized emergency response telephone number; and other infractions of the HMR. Penalty: $6,230

  15. Recent Violations Kay Chemical Company Winston-Salem, NC (Shipper) Offered sodium hydroxide solution, 8, in unauthorized non-UN standard packaging. [173.202(b), 173.22(a)(2)] Penalty: $3,935

  16. Recent Violations Gem Gravure Company, Inc. West Hanover, MA (Shipper) Offered printing ink, 3, accompanied by a shipping paper that failed to include a unit of measure; and other infractions of the HMR. [172.802(a)(3), 172.202(a)(5), 172.800(a)] Penalty: $2,000

  17. Recent Violations 220 Laboratories, Inc. Riverside, CA (Shipper) Offered flammable liquid, n.o.s. (ethyl alcohol), 3 in unauthorized non-UN standard plastic drums; offered flammable liquid, n.o.s. (ethyl alcohol), 3, accompanied by a shipping paper that: • provided an incorrect packing group, • failed to use the proper packing group format, • interspersed unauthorized information within the basic shipping description, • provided unauthorized abbreviations, • contained a shipping description that was not in proper sequence, • failed to provide the technical name of the hazardous material in parentheses, and • failed to provide a total quantity of material; And failed to label non-bulk packages of hazardous material. Penalty: $13,000

  18. Recent Violations Epmar Corporation Santa Fe Springs, CA (Shipper) Offered caustic alkali liquid, n.o.s. (alkyl ether amine), 8, in an unauthorized non-UN standard non-bulk packaging; failed to mark packagings containing liquid hazardous material with the required orientation markings. [173.203(c), 173.24(c)(1), 172.312(a)(2), 173.22(a)(2)] Penalty: $6,875

  19. Recent Violations Chemlogic, Inc. Rayne, LA (Shipper) Failed to close packaging in accordance with the manufacturer's closure notification. [173.22(a)(4), 173.24(f)(2)] Penalty: $1,750

  20. Shipping Paper Violations • Failure to include a description in parentheses following “N.O.S.” carries a minimum fine of $1,200. • Failure to prepare shipping papers when transporting hazardous materials carries a minimum fine of $5,200.

  21. Waste Transportation Checklist See Appendix A in Student Manual

  22. US DOT Hazardous Materials • Definition • General • Hazard Classes • Shipping Papers • Bill of Lading • Hazardous Waste Manifest

  23. Manual pg. 3 Hazardous Materials Table • Alphabetical list of hazardous materials • Column 1: Symbols • Column 2: Shipping Name • Font Exceptions • Bold entry vs. italic description • Column 3: Hazard Class • Column 4: ID Number, (UN vs NA) • Column 5: Packing Group • Column 6: Labels • Column 7: Special Provision • Column 8: Packaging Authorizations • 8A Exceptions, 8B Non-bulk, 8C Bulk • Column 9: Quantity limitations for aircraft and rail • Column 10: Vessel storage requirements

  24. Manual pg. 5 Proper Shipping NamesAdditional Descriptions • “Solution” or “Mixture” • “Waste” • Generic Shipping Names or “Not Otherwise Specified” (N.O.S.) • “Reportable Quantity” or RQ

  25. Manual pg. 9 Poison-Inhalation Hazards • The words “Poison-Inhalation Hazard, Zone ____” • Look in Column 7 of the Hazardous Materials Table. • Zones A, B, C, D

  26. Poison-Inhalation Hazards • Bromine, 8, UN1744, PGI, Poison-Inhalation Hazard, Zone A. • Placard any quantity, in addition to any other placards required.

  27. TRANSPORTATION VIOLATIONS AND PENALTIES • COCA-COLA BOTTLING CO. CONSOLIDATED • Failed to mark a package “Inhalation Hazard” when required; failed to properly label hazardous materials container or package; failed to provide emergency response information; transported a hazardous materials shipment without a proper shipping paper. [172.301(a), 172.400(a), 172.600(c)(1), 177.817(a)] Penalty: $10,000

  28. Manual pg. 9 Dangerous When Wet Materials • The words “Dangerous When Wet” • Column 6 of the Hazardous Materials Table. • Placard any quantity, in addition to any other placards required

  29. Manual pg. 9 Marine Pollutant Appendix B of the Hazardous Material Table and that are packaged in a solution or mixture of one or more Marine Pollutants in concentrations which equal or exceed …..

  30. Marine Pollutant • 10% by weight of the solution for materials listed in Appendix B; or, • 1% by weight of the solution or mixture for materials that are identified as Severe Marine Pollutants in Appendix B.

  31. Marine Pollutant • The words “Marine Pollutant” must be entered on shipping papers and labels • Proper shipping name must identify the marine pollutant by name. Otherwise, name must be listed in parenthesis following the shipping description.

  32. Marine Pollutant • Class 9 material • “Environmentally Hazardous Substance, Liquid or Solid, N.O.S. (marine pollutant name)”

  33. Marine Pollutant Marine Pollutant US DOT labels are not required for non-bulk packages being transported by air, rail, or highway.

  34. Marine Pollutant Bulk packages of marine pollutants must be marked with the Marine Pollutant label, unless the bulk package is already placarded for another hazard class.

  35. Manual pg. 14 Packing Groups • Column 5 • Does not apply to hazard class 2, 7, Division 6.2 and ORM-D materials. • Packing GroupDanger Presented by Material PG I Great Danger PG II Medium Danger PG III Minor Danger

  36. Proper Shipping Descriptions Question #1 Is the following a proper shipping description? 1,1 Dichloroethane, 3, UN2362, PG II If not, what is the proper shipping description?

  37. Proper Shipping Descriptions Answer #1 Yes.

  38. Proper Shipping Descriptions Question #2 Is the following a proper shipping description? Potassium Hydroxide, Solution, UN1816, 8, PG III If not, what is the proper shipping description?

  39. Proper Shipping Descriptions Answer #2 Potassium Hydroxide, Solution, 8, UN1814, PG II

  40. Proper Shipping Descriptions Question #3 What is the proper shipping description for lead acid batteries?

  41. Proper Shipping Descriptions Answer #3 Batteries, Wet Filled with Acid, 8, UN2794, PG III

  42. Proper Shipping Descriptions Question #4 What is the proper shipping description for a drum of acetone?

  43. Proper Shipping Descriptions Answer #4 Acetone,3, UN1090,PGII

  44. Proper Shipping Descriptions Question #5 What is the proper shipping name for a drum of spent Allyl Alcohol?

  45. Proper Shipping Descriptions Answer #5 Waste Allyl Alcohol, 6.1, UN1098, PG I, Poison-Inhalation Hazard, Zone B

  46. Proper Shipping Descriptions Question #6 What is the proper shipping description for a waste mixture of 50% acetone and 50 % hexane? The boiling point of the material is 96 degrees Fahrenheit and the flashpoint of the material is 70 degrees Fahrenheit?

  47. Proper Shipping Descriptions Answer #6 Waste Flammable Liquid, N.O.S. (Acetone, Hexane), 3, UN1993, PG II

  48. Proper Shipping Descriptions Question #7 Is Muriatic Acid a proper shipping name?

  49. Proper Shipping Descriptions Answer #7 No.

  50. Proper Shipping Descriptions Question #8 Is the following a proper shipping description? MEK, 3, UN1193, PG III If not, what is the proper shipping description?

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