How to Ship Hazardous Waste Samples
But how can you be accurate if you don’t have all the information you need about a waste? Most likely, you’ll want to send a sample to a laboratory for testing. Now that’s a conundrum! How can you ship the sample?
This predicament can arise in a couple of scenarios. It might happen if you’ve generated a new hazardous waste and are uncertain about its constituents or properties. It may also happen when there is a spill or leak of hazardous waste that mixes with other substances, soil, debris, or emergency response chemicals.
Exclusion for Hazardous Waste SamplesFirst, a sample of solid waste or a sample of water, soil, or air, which is collected for the sole purpose of testing to determine its characteristics or composition, is not subject the RCRA hazardous waste regulations if it meets certain criteria specified at 40 CFR 261.4(d).
The sample may still be regulated as a DOT hazardous material, however.
Assigning a Proper Shipping Name, Hazard Class, and Packing GroupFortunately, there are special rules at 49 CFR 172.101(c)(11) to ship a sample of a material that is a hazardous waste or a sample of a material for which the hazard class is uncertain and must be determined by testing.
The material may be assigned a tentative proper shipping name, hazard class, UN identification number, and packing group (if applicable) based on the shipper's tentative determination. These tentative assignments may be based on the shipper’s knowledge of the material. In addition:
- Except when the word “Sample” already appears in the proper shipping name appearing on the §172.101 Hazmat Table, the word “Sample” must appear as part of the proper shipping name or in association with the basic description on the shipping paper.
- When the proper shipping description for a sample is assigned a “G” in Column (1) of the §172.101 Hazmat Table, and the primary constituent(s) for which the tentative classification is based are not known, the provisions requiring a technical name for the constituent(s) do not apply.
- Do not add the word “waste” to the proper shipping name.
Packaging a Hazardous Waste SampleA sample must be transported in a combination packaging applicable to the tentative packing group assigned.
The net mass (i.e., the weight) of the sample may not exceed 2.5 kg (i.e., approximately 5.5 pounds) per package.
Hazmat Marks and LabelsPackages of hazardous waste samples will be marked and labeled as any other fully regulated package will be.
Shipping PapersBecause hazardous waste samples are excluded from RCRA regulation (under certain conditions), a Uniform Hazardous Waste Manifest is not required for offsite shipment. However, DOT hazmat shipping papers are required.
Keep in mind, however, that these rules are not available for samples of forbidden materials, explosives, new self-reactives or organic peroxides.
Once testing is complete and you know more about your waste, you can properly manage, store, and ship it in compliance with the applicable RCRA and US DOT regulations.
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Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.
The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.
Amazing instructor; real-life examples. Lion training gets better every year!
Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.
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These are the best classes I attend each year. I always take something away and implement improvements at my sites.
I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.
The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.
Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.
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This is the best RCRA training I've experienced! I will be visiting Lion training again.
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Some limited quantity reliefs are reserved for specific modes of transport. Use this guide to identify which reliefs you can capitalize on, and which do not apply to your operations.