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PHMSA Answers Frequently Asked Hazmat Questions

Posted on 4/11/2022 by Roseanne Bottone and Roger Marks

US DOT PHMSA will compile and publish a series of Frequently Asked Questions (FAQ) to provide clear information about compliance to hazardous materials shippers, manufacturers, and other stakeholders.

PHMSA’s first batch of FAQs will focus on the applicability of the Hazardous Materials Regulations (HMR)— who and what the regulations apply to, in other words. 

The forthcoming FAQs are not legal requirements. They are meant to clarify, explain, and help stakeholders to interpret the regulations. By making this information easier to find, DOT hopes to eliminate repeated requests for specific Letters of Interpretation.  

The notice includes examples of twelve frequently asked questions (with answers), including:
  • Is a hazardous material subject to the HMR that only crosses a public road?
  • Are state universities subject to the HMR when transporting hazardous materials?
  • Are gasoline cans transported by a landscaping company by motor vehicle subject to the HMR?
See the announcement, including the sample FAQ questions and answers, in the March 22 Federal Register.

DOT PHMSA asks stakeholders to submit public comments and suggestions for future FAQ topics by May 23, 2022.

Who Must Follow the HMR?

A company of any size that offers hazardous materials into the cycle of transportation by motor vehicle, rail, air, or vessel must comply with US DOT’s Hazardous Materials Regulations in 49 CFR Parts 100—181, et al. The rules apply to any quantity of hazardous materials (including hazardous waste) transported in commerce.

There are no exemptions for small businesses—even self-employed people who ship hazardous materials as part of their job must comply with the HMR. That includes providing training for employees as required by 49 CFR 172.704.

Effective hazmat employee training is critical to ensure compliance with the HMR. These regulations include extensive and detailed requirements for classifying and naming regulated materials, selecting authorized packaging, filling and closing packagings, applying required markings and labels, documenting shipments and more.

Who Needs Hazmat Training?

US DOT requires training for all hazmat employees—defined in 49 CFR 171.8 as “A person who…directly affects hazardous materials transportation safety.”

This includes full time, part time, or temporary employees who load, unload, or handle hazardous materials; prepare hazardous materials for transportation; operate a vehicle used to transport hazardous materials; design or test packaging; and others.

For more details about who must comply with the HMR, who needs hazmat training, and more, see Lion’s Hazmat Training FAQ.

Hazmat & RCRA FAQs at Lion.com

Lion maintains frequently asked questions pages for hazardous materials, safety, and environmental professionals, focused on the training requirements for managers and employees.

Lion Members can access more in-depth FAQs, developed over forty-five years of experience in industry. Members also can submit questions to Lion instructors and subject matter experts through the Finder Service. One year of Lion Membership is included with enrollment in any Lion workshop or webinar, or an equivalent online course.

Lion Members: Hazmat Shipping FAQ

Instructor-Led DOT Hazmat Training 

Join a workshop or webinar for live, instructor-led training to ship hazardous materials in full compliance with the latest US and international regulations for ground, air, and vessel shippers. 

The two-day Hazmat Ground Shipper Certification (DOT) Workshop comes to Cincinnati, St. Louis, San Diego, Denver, Nashville, Orlando, Dallas, and Houston this year,  

Upcoming Webinars

Hazmat Ground Shipper Certification (DOT) May 17–18
Recurrent Hazmat Ground Shipper Certification (DOT)  May 2
Hazmat Air Shipper Certification (IATA) May 3
Hazmat Vessel Shipper Certification (IMDG) May 4
Shipping Lithium Batteries April 26

Prefer to train at your own pace? Choose an interactive, mobile-ready online course to ship hazardous materials, manage hazardous waste, prepare for emergencies, and comply with OSHA workplace safety regulations. Visit Lion.com/Online.

Tags: DOT compliance, hazardous materials regulations, hazmat shipping

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