Q. We are a conditionally exempt small quantity generator (CESQG). We hold waste on site in a central storage area for up to six months before we ship everything off site, but we don’t follow the actual 180–day rules while we’re storing the waste. We mark the words “Hazardous Waste” on our containers but nothing else. Since some of the waste is flammable, do we need to label the containers with either DOT labels or OSHA hazard communication labels while we’re storing them...
Q. I’ve heard the U.S. Department of Transportation (DOT) is phasing out the Consumer Commodity (ORM-D) exceptions from the Hazardous Material Regulations (HMR; 49 CFR parts 171-180). When did this happen? When does it take effect? And does this mean that regular consumer products need shipping papers and the whole rigmarole of marks, labels, and UN specification packaging like regular hazmat...
Q. Our pick-and-pack operation ships lots of different kinds of hazardous material in many arrangements. Some of our boxes have up arrows, some do not. When do we need to use up arrows? Is there any time we can’t use them? A. Orientation arrows, or “up arrows,” are required whenever you ship hazardous materials in one of these packages...
A hazmat self-audit is a best practice that can help you ace a hazmat inspection, protect personnel, and defend against civil and criminal penalties. Use this report to identify best practices, avoid common shipping mistakes, and sidestep the pitfalls that trigger DOT inspections.