ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 15

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Hazardous Waste and DOT

Q. Do I have to have hazardous materials training if I ship out hazardous waste?
A.Yes. If a person is shipping an EPA-regulated hazardous waste and that waste is required to be shipped on a manifest, then that material is subject to the DOT Hazardous Materials Regulations. In fact, there is a specifically worded certification statement on the manifest that certifies that the shipment complies with all applicable DOT requirements.

Wording on the Battery

Q. Do the words “Lithium Battery” have to be on the actual battery?
A. No, there is no requirement in the regulations to have those words on there. However, almost all of the transport regulations have added the requirement to include the watt-hour or gram content on the outer cases of said batteries.

HMIS

Q. I have some questions about HMIS ratings. Do you know where I can find more information on that? I’m having a hard time determining what PPE is needed at my facility.
A. We offer HMIS ratings as a service at ICC. As to the PPE component, the better course of action is to use the SDS and any risk assessment data at the facility to make those determination. Continue Reading…
Environmental Update
EPA e-Manifests Open to Waste Generators

Using computer near truck

Are You Ready for e-Manifests?

Paperwork – it’s one of the worst parts of dealing with hazardous waste shipments. In both Canada and the United States, hazardous wastes require a special document, the Waste Manifest that will not only serve as the transportation document for the dangerous goods/hazardous materials transportation regulations, but also allow environmental authorities to track the waste from the generator, who sends it for disposal, through the hands of the carrier, to the end receiver (in the US referred to as a TSDF, for Hazardous Waste Treatment, Storage and Disposal Facility).

In Canada, some jurisdictions have eased the burden by allowing the waste manifest to be created electronically. For example, in Ontario, the HWIN system has been used for years. However, until now, the United States has not had a system for electronic documentation, called e-Manifests. On June 30, 2018, that has changed.

The change has been a long time coming. Although the initial proposal by the Environmental Protection Agency (EPA) was made in 2001, it was not until 2012 that Congress passed the “Hazardous Waste Electronic Manifest Establishment Act.” Under the Act, a final rule was published in 2014 that approved the use of such manifests. Since then, the EPA has been working to create an online system that will allow the e-manifest to eliminate substantial chunks of the burden of manifests, as well as Continue Reading…