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More Packaging Info
Dear Radsafers:
Here's some info relating to the last week's packaging thread. It was put
out by Ralph Stuart on the SAFETY listserver last Friday. It also contains
some internet resources that relate to the packaging and transportation
standards for hazardous materials. I don't think anybody re-posted to
RADSAFE (excuse me if it has been).
Thanks Ralph!
-Erick Lindstrom
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This is an article Milly and I wrote for the Vermont Environmental Monitor,
a monthly newsletter tracking the environmental regulatory process
in Vermont. For subscription information or a sample copy of the Monitor,
call 800/639-6074 or visit their web site at http://www.sover.net/~ppress/.
- Ralph
Transportation Regulations for Hazardous Materials
The transportation of hazardous materials poses a potential risk to the
general public and the environment. Because of the threat of human exposure
to dangerous chemicals and the environmental damage which can result from a
transportation accident involving hazardous materials, their movement is
highly regulated.
The goals of these regulations are to assure that: 1) hazardous materials
are packaged so they are unlikely to be spilled under normal transit
conditions; 2) people who handle the packages are aware of their contents
and potential hazards; and 3) emergency responders can quickly identify and
assess the hazards that the materials present if there is an accident.
Currently, new hazmat transport regulations are being phased in which make
significant changes to the hazmat transportation regulatory scheme. This
article gives an overview of these regulations.
In 1974, the Hazardous Materials Transportation Act gave the Department of
Transportation (DOT) the authority to regulate the movement of substances
that pose a threat to human health and safety, property, or the environment
when the substances are transported by air, highway, rail, or water. In
1990, the Transportation Uniform Safety Act became law. The goal of this
act was to create a uniform system for transporting hazardous materials and
to bring U.S. regulations on hazmat packaging and transportation in line
with the United Nations standards used worldwide. This law led to
promulgation of the Hazardous Material Regulation 181 (HM-181). HM-181 has
a 10 year phase-in plan from 1991, although most transporters follow it
completely now. This regulation gives new responsibilities to shippers and
transporters of hazardous materials and manufacturers of shipping
containers.
Major features of HM-181
HM-181 affects everybody involved with moving hazardous materials in
commerce. Generally speaking, if you transport any amount of a hazardous
material over a public highway, including city streets, you are governed by
these regulations. There are limited exemptions to the regulations for
"sample" sized containers being shipped. These quantities are less than a
few ounces. There are six primary features of HM-181. They work together to
produce a labelling and handling system that allows shipments of hazardous
materials to travel in a protected manner.
1. Hazardous Materials Table: A hazardous materials table provides the
basic information required to classify and identify a material as hazardous
within the DOT system. The Hazardous Material Table gives the proper
shipping name, hazard class and UN identification numbers, packing group,
and any labels and specific packaging types necessary for a particular
hazardous material. The table, which takes up more than 200 pages, is found
in 49 CFR 172.101, and is commonly available from many commercial sources.
There is also a computer program called the HazMat Shipper available which
is designed to make using this table easier. Information about it can be
found at http://wwwreg.ihsreg.com/~logistics_lib/hms.htm.
2. Hazard Classes: There are nine hazard classes used to group hazardous
materials in the DOT system. Each hazard class is given a number that
identifies the hazard of the material. Both the hazard class and division
for a particular material are given in the Hazardous Materials Table. The
hazard classes are:
1. Explosives (divided into six groups);
2. Gases (divided into three groups: 2.1 Flammable, 2.2 Nonflammable, and
2.3 Poison gases);
3. Flammable and Combustible Liquids;
4. Solids (three divisions: 4.1 Flammable, 4.2 Spontaneously Combustible
and 4.3 Dangerous When Wet);
5. Oxidizing Agents (two divisions: 5.1 Oxidizer and 5.2 Organic Peroxides);
6. Poisons (two divisions: 6.1 Poison and 6.2 Infectious Substances);
7. Radioactive;
8. Corrosives; and
9. Miscellaneous
3. Markings, Labels and Placards: Packages and vehicles containing
hazardous materials must be labelled using markings, labels and placards.
Markings are labels on the package which contain the proper shipping name,
the UN/NA (United Nations/North American) identification number, and the
sender or receiver's name and address. There is no required format for this
information, but it must be easily indentifiable. Labels are four by four
inch diamonds which indicate the primary hazard or special precautions
specific to the hazard class of the material. These labels have strict
specifications involving the color, size, wording and placement on the
container. DOT hazmat labels are commercially available. A subsidiary label
may be required in addition to the primary lable if indicated on the
Hazardous Materials Table. Placards are similar to labels, but are 10-3/4"
square diamonds which are placed on the transporting vehicle.
Specifications for placards include their color, size and wording as well
as where they must be put on the shipping vehicle. For most hazardous
materials, placards are not required for shipments under 1000 pounds;
however some hazardous materials require placards for any quantity. Consult
the hazardous materials table for more information.
4. Performance Standards and Specifications for Packaging: The packaging
standards of HM-181 are based on the package's performance under stresses
that might be encountered during transportation. Particular specifications
for packages have been eliminated; instead packaging must pass performance
tests so that manufacturers can develop new and innovative types of
packaging. The packaging standards are based on the UN Recommendations, and
are divided into three groups: I, II and III. Group I is designed to
contain the most hazardous chemicals, while Group III is for the least
hazardous. In addition, different types of containers are assigned
identification numbers, which describe the type of container, its packing
group and age, among other things. A more complete description of the
packaging requirements can be found at
http://www.labelmaster.com/transprt/package2.html
5. Emergency Response Information: HM 181 specifies that information about
how to handle the hazardous material during an accident or other emergency
must be provided to and carried by the shipper. The regulation requires
emergency response information to be available with the shipping papers (a
bill of lading or hazardous waste manifest) when hazardous materials are
transported. The emergency response information must discuss the fire and
health hazards of the materials being shipped, the appropriate emergency
actions to be taken, and proper first aid techniques. This information can
be put directly on the shipping paper or, more commonly, included in an
emergency response document or a material safety data sheet carried by the
driver. The DOT has put together a Emergency Response Guide (ERG) based on
the hazard groups discussed above which is available from a variety of
sources. A 24-hour emergency contact telephone number must also be provided
on the shipping paper in a clearly visible location. The telephone number
must be the number of a person who is knowledgeable about the hazardous
material being shipped or has access to the information.
6. Training of Employees: Employee training on hazmat safety and the major
features of the regulations is also required by HM 181. Employers must
provide training for all hazmat employees, including people who prepare
shipping documents, pack hazardous materials, mark and label containers,
prepare or handle the containers used in transporting hazardous materials,
or operate a vehicle used to transport hazardous materials. This training
includes a general knowledge of the regulations, specific training
applicable to the employee's job, and safety training on emergency
response. OSHA or EPA training can often be used to satisfy this training
requirement, although DOT training is often required for employees who
aren't covered by other hazmat regulations. Refresher training is required
at least once every two years. Computer-based training packages are
available to help with this task. See, for example,
http://indusnet.org/business/utah/williams/hazmat.html.
Recent Developments
Because HM 181 regulations are being phased in over a ten year period,
minor changes and adjustments to the regulations can be expected. These are
usually in the form of amendments and updates to the Hazardous Materials
Table or clarifications of specific parts of the rule. After October 1,
1996, hazardous materials in transportation must be packaged in containers
meeting the UN packaging standands discussed above.
The Emergency Response Guide is currently being updated and, according to
the DOT hotline, will be available in May. This edition of the Emergency
Response Guidebook, the "North American Emergency Response Guidebook,"
(NAERG), will be published in English, French and Spanish. It covers
approximately 3,625 of the chemical names included in the 49 CFR Hazardous
Materials Table, as well as the UN 9th Edition, the International Civil
Aviation Organization's (ICAO) Dangerous Goods Regulations, International
Maritime Dangerous Goods Code (IMDG), the Canadian Transport of Dangerous
Goods (TDG), Mexico's hazardous materials regulations and some pre-HM-181
proper shipping names that could still be encountered by emergency response
personnel. The new guidebook uses a three-digit numbering system for guide
pages to distinguish itself from previous guidebook editions. The book also
contains revised information on protective action distances and new
information about the use of personal protective clothing for emergency
responders.
Conclusion
If you find the DOT regulations governing hazardous materials confusing or
cumbersome, you are not alone. Fortunately, help is available. One place to
start looking is at http://cti1.volpe.dot.gov/ohm/home.html, which is the
home page of the Department of Transportation's Office of Hazardous
Materials Safety. A commercial web page with helpful leads is
http://www.chiltonco.com/hazmat/. This provides access to various contacts
within the DOT and some information about how the federal government is
interpreting the regulations. There are also many commercial training
packages and suppliers of materials such as package labels, bill of lading
forms and other required materials. Check with your safety supplier for
help.
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Erick Lindstrom
Radiation Safety Officer
309 Montana Hall
Montana State University
Bozeman, MT 59717-0244
Phone: (406) 994-2108
Fax: (406) 994-4792
avrel@gemini.oscs.montana.edu