printreg,June,2004Pre Waste Transport Responsibilities

printreg, June, 2004
Pre Waste Transport Responsibilities


New Message Reply About this list Return to Date view Return to Thread view Return to Subject view Return to Author view
From: Debra Jacobson(
djacobson@istc.illinois.edu)
Date: Wed, 16 Jun 2004 07:51:31
These requirements are in addition to the EPA requirement to obtain a hazardous waste identification/generator number, complete the hazardous waste manifest, complete the land disposal restriction forms where applicable, determine the appropriate name of the waste, determine proper labeling, etc.
Debra Jacobson

---------------------------------------------------------------------------------------------------------------------------------

To ensure that hazardous materials (including hazardous waste) will reach their destination safely, DOT has established requirements in the hazardous material regulations that apply to anyone that offers or transports a hazardous material for transportation in commerce. These requirements extend to persons who either perform a pre-transportation function (49 CFR 171.1) or are responsible for overseeing a pre-transportation function. These functions are in addition to transportation functions such as those that are performed when the material is actually on the highway. See http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_49/49cfr171_00.html

Pre-transportation functions include but are not limited to:
* Determining the hazard class of a hazardous material
* Selecting a hazardous material packaging
* Filling a hazardous material packaging, including a bulk packaging
* Transloading a hazardous material at an intermodal transfer facility from one bulk packaging to another bulk packaging for purposes of continuing the movement of the hazardous material in commerce
* Securing a closure on a filed or partially filed hazardous material package or container or on a package or container containing a residue of a hazardous material
* Marking a package to indicate that it contains a hazardous material
* Preparing a shipping paper
* Providing and maintaining emergency response information
* Reviewing a shipping paper to verify compliance with the HMR or international equivalents
* For each person importing a hazardous material into the United States, providing the shipper with timely and complete information as to the HMR requirements that apply to the transportation of the material within the United States
* Certifying that a hazardous material is in proper condition for transportation in conformance with the requirements of the HMR
* Loading, blocking, and bracing a hazardous materials package in a freight container or transport vehicle Segregating a hazardous materials package in a freight container or transport vehicle from incompatible cargo
* Selecting, providing, or affixing placards for a freight container or transport vehicle to indicate that in contains a hazardous material.

Personnel that perform any of the pre-transportation functions described above are subject to all applicable hazardous material regulations, including the training requirements at 49 CFR 172.700. See http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=e4454683f0da043c58be2371283f1e49&rgn=div6&view=text&node=49:2.1.1.3.7.8&idno=49

Source: Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center



New Message Reply About this list Return to Date view Return to Thread view Return to Subject view Return to Author view