Hazardous Materials (TDG, PHMSA)

The transportation of hazardous materials (hazmat) has unique safety and regulatory requirements. We provide the following services:

 

Permitting

We assist companies in getting the proper state and federal permitting to transport hazardous material via highways, or vessel.

 

Hazardous Materials Training

In addition to the communications requirements that took effect on October 1, 1993, hazmat employers must have trained hazmat employees hired prior to 07/02/93. For a complete definition of ‘hazmat employer’ and ‘hazmat employee’ please see definitions contained in appendix A.

 

Training Required

front of delivery truck showing what hazard material it is shippingGeneral awareness/familiarization: General awareness and familiarization training is intended to raise the hazmat employees’ awareness of the Hazardous Materials Regulations (HMR) and the purpose and meaning of the hazard communication requirements. All hazmat employees must have this training.

Function-specific training

Function-specific training is intended to teach the necessary knowledge, skills, and abilities for an individual’s job function.

Safety training

This training provides information concerning the hazards posed by materials in the workplace and personal protection measures. The training may include basic emergency response procedures but is not intended to satisfy the requirements of 29 CFR 1910.120.

Security Training

Each hazmat employee must receive security awareness training. This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. After March 25, 2003, hazmat employees must receive this training at their next scheduled recurrent training, but in no case later than March 24, 2006. New hazmat employees must receive this training within 90 days of employment.

In addition to the above security awareness training, hazmat employees of employers that are required to have a security plan must receive in-depth security training on the security plan and its implementation.

Modal specific requirements

Any additional training required by 49 CFR PARTS 174, 175, 176, or 177.

The regulation does not specify sources of training. The US Department of Transportation does not designate sources of training nor certify training courses, instructors, and/or schools. It is the hazmat employer’s responsibility to determine the adequacy of the training being presented. Training may be in any appropriate format including lecture, conference, self-paced instruction, interactive video, etc.

We provide IMDG Training: The International Maritime Dangerous Goods (IMDG) Code is a set of regulations related to the shipping of dangerous goods by vessel. IMDG training requirements are related rules that dictate who must receive maritime dangerous goods training and IMDG certification.

 

Applicability

The hazardous materials regulations are applicable to the transportation of hazardous materials in commerce and their offering to:

  • Interstate, intrastate, and foreign carriers by rail car, aircraft, motor vehicle, and vessel.
  • The representation that a hazardous material is present in a package, container, rail car, aircraft, motor vehicle, or vessel.
  • The manufacture, fabrication, marking, maintenance, reconditioning, repairing or testing of a package or container which is represented, marked, certified or sold for use in the transportation of hazardous materials (49 CFR 171.1(a))

“No person may offer or accept a hazardous material for transportation in commerce unless that person is registered in conformance with subpart G of Part 107 of this chapter, if applicable, and the hazardous material is properly classed, described, packaged, marked, labeled, and in condition for shipment as required or authorized…”(49 CFR 171.2(a))

 

Hazardous Materials Carrier Responsibility

  • Shipping paper
  • Placard and mark vehicle
  • Loading and unloading
  • Compatibility
  • Blocking and bracing
  • Incident reporting
  • Security plan
  • Employee training

 

Security Plans

Red Fire sign with 3494 fire symbol and white toxic inhalation hazard sign, warning signs on metal tank truck back, dangerous materials transportationWe do site assessments as well as write HazMat security plans for companies.

The security plan requirements in Part 172 Subpart I of the Hazardous Materials Regulations (HMR) require each hazmat employer subject to the security plan requirements to establish and implement a security plan. The employer is also required to train their hazmat employees on the security plan. The purpose of these requirements is to enhance the security of hazardous materials transported in commerce. Employers must establish and implement their security plan by September 25, 2003, and by December 22, 2003, each employee must receive training on the security plan and its implementation.

Security Plan Applicability

Each person who offers for transportation in commerce or transports in commerce one or more of the following hazardous materials must develop and adhere to a transportation security plan for hazardous materials that conforms to the requirements of this subpart. As used in this section, “large bulk quantity” refers to a quantity greater than 3,000 kg (6,614 pounds) for solids or 3,000 liters (792 gallons) for liquids and gases in a single packaging such as a cargo tank motor vehicle, portable tank, tank car, or other bulk container.

  1. Any quantity of a Division 1.1, 1.2, or 1.3 material;
  2. A quantity of a Division 1.4, 1.5, or 1.6 material requiring placarding in accordance with subpart F of this part;
  3. A large bulk quantity of Division 2.1 material;
  4. A large bulk quantity of Division 2.2 material with a subsidiary hazard of 5.1;
  5. Any quantity of a material poisonous by inhalation, as defined in §171.8 of this subchapter;
  6. A large bulk quantity of a Class 3 material meeting the criteria for Packing Group I or II;
  7. A quantity of desensitized explosives meeting the definition of Division 4.1 or Class 3 material requiring placarding in accordance with
    subpart F of this part;
  8. A large bulk quantity of a Division 4.2 material meeting the criteria for Packing Group I or II;
  9. A quantity of a Division 4.3 material requiring placarding in accordance with subpart F of this part;
  10. A large bulk quantity of a Division 5.1 material in Packing Groups I and II; perchlorates; or ammonium nitrate, ammonium nitrate fertilizers, or ammonium nitrate emulsions, suspensions, or gels;
  11. Any quantity of organic peroxide, Type B, liquid or solid, temperature controlled;
  12. A large bulk quantity of Division 6.1 material (for a material poisonous by inhalation see paragraph (5) above);
  13. A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR part 73 or the United States Department of Agriculture under 9 CFR part 121;
  14. A quantity of uranium hexafluoride requiring placarding under §172.505(b);
  15. International Atomic Energy Agency (IAEA) Code of Conduct Category 1 and 2 materials including Highway Route Controlled quantities as defined in 49 CFR 173.403 or known radionuclides in forms listed as RAM-QC by the Nuclear Regulatory Commission;
  16. A large bulk quantity of Class 8 material meeting the criteria for Packing Group I.