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…
Labeling
HMIS and NFPA: Do They Still Work?

Now that OSHA has revised the Hazard Communication Standard to align with GHS, the question many employers, chemical manufacturers, distributors and end users have is: Will I be able to continue to use my NFPA and HMIS labeling systems?

The answer is yes . . . But they may cause confusion. The question becomes not whether you can, but whether you should.

First, let’s look at the old standard’s requirements. In the old standard (pre-HazCom 2012), labels (and labeltext) on shipped containers and workplace labels were performance based. That means OSHA didn’t say exactly what had to appear on the labels. Instead, it said what effect the labels had to achieve; OSHA’s goal: to successfully transmit hazard information to the end user.

Many companies adopted either the NFPA or HMIS system for workplace labeling. Both systems are simple and effective. A criteria was established to identify the health, physical, reactivity and personal protective equipment that was required. A numerical system from 0-4 identified the hazard from lowest (0) to worst (4).

Simple right? Well it was until HazCom 2012 adopted the GHS recommendations and added health and physical criteria and categories. Now, a chemical that was previously a number “1” meaning it had a low hazard, is now a “4” meaning it has a low hazard.

What’s an employer to do? If you have used a number based workplace system in Continue Reading…