Lion News September 2022

Alfredo Sauce: A Reportable Release?

Posted on September 01, 2022 by Roger Marks

A tractor-trailer hauling glass jars of alfredo sauce crashed into a wall near Memphis, Tennessee on Tuesday, August 30. The incident occurred at about 4:30 PM and coated the northbound lanes of I-55 in creamy, cheesy sauce.

Clean up progressed past 9 PM, disrupting traffic traveling both ways for hours. The driver of the truck was transported to a hospital with minor injuries, according to reports. Full story (and photos) here.

The alfredo sauce incident occurred one day after a truck spilled tomatoes across I-80 in California on a Monday morning. While messy, spills of alfredo sauce or tomatoes don’t pose an imminent threat to human health. Still, these unusual incidents are a reminder of the inherent risks of transporting cargo of all kinds.

They also give us a reason to consider some of the major release reporting provisions that may apply when transportation incidents involve hazardous materials or substances.

Reporting Hazardous Materials Releases

Alfredo sauce is not listed on the Hazardous Materials Table in 49 CFR 172.101 (I checked). So no hazmat transportation-related release reporting was required in this case.

If it were acetone instead of alfredo sauce that spilled, a report would have been required.

When a hazardous material is released in transportation, the person in possession of the material must file an incident report with US DOT using Form 5800.1. Unintentional releases of a hazardous material are one trigger for a written report that must be submitted within 30 days.

An “unintentional release” could be a major spill or a minor incident, like a single box failing in transportation.

Some hazmat transportation incidents must be reported immediately to the National Response Center (NRC). Releases that require an immediate report are those that result in death, injury, evacuation, or major transportation disruption. When an immediate report is required, a written report must follow.

Read more: Lessons from 3 Real Hazmat Incident Reports

Hazardous Substance Releases Under CERCLA/Superfund

What about reporting under the CERCLA/Superfund program? CERCLA requires immediate reporting by phone to the NRC for all releases of “hazardous substances” at or above the Reportable Quantity or RQ. The list of hazardous substances, along with a reportable quantity for each one, is found in 40 CFR 302.4.

Alfredo sauce is not listed as a hazardous substance, but the CERCLA list is growing—EPA recently proposed adding two prevalent per- and polyfluoroalkyl substances (PFAS) to the list.

Read more: PFOA, PFOS Proposed as Superfund Substances

As of now, no such proposal is in the works for alfredo sauce.

 
 

Clean Water Act Oil Discharge Rules (40 CFR Part 110)

When we think of an oil spill, most of us think of petroleum products first. But the Clean Water Act definition of “oil” is broad—it includes animal fats and oils, vegetable oils, nut oils, seed oils, and more.

Because of its animal fat content, even milk can be considered “oil” under the Clean Water Act. In fact, facilities that store large quantities of milk were required to maintain an oil Spill Prevention, Control, and Countermeasure (SPCC) Plan until EPA added an exemption to the regulations in 2011.

The Discharge of Oil requirements in 40 CFR Part 110 require reporting to the NRC when a “harmful quantity” of oil is discharged to a Water of the United States or WOTUS.

A “harmful quantity” is not defined as a specific amount of oil, but rather as any quantity that:

  • Violates applicable water quality standards;
  • Causes a film or sheen on the water’s surface; or
  • Leaves sludge or emulsion beneath the surface.

(40 CFR 110.3)

Depending on the ingredients, alfredo sauce likely contains some animal fat or oil and would probably leave a sheen or film on the water’s surface. If last week’s release had reached a navigable water, those involved would have had to at least consider reporting it as an oil spill.

Last Word

The highway-stopping release of alfredo sauce reminds us that the rigors of transportation can put major stress on packaging and cause large amounts of product to be lost.

When hazardous materials are involved, the consequences are much more serious.

Adequate packaging and package closures are mission critical if you ship hazardous materials. Release reporting provisions under the HMR, CERCLA, the Clean Water Act, and more help to protect the public and ensure that effective cleanup can start as soon as possible.

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