Tag: DOT

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Are You A Registered HazMat Shipper?

PHMSA HazMat Registration is due for 2020-2021. Registration is valid from July 1 – June 30.

Who needs to register?

You must register if you are a person who offers for transportation or transports in commerce a shipment containing any of the following categories of hazardous materials (including hazardous wastes):

  1. A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in 49 CFR 173.403. A “highway route-controlled quantity” may be shipped by highway, rail, air, or water.
  2. More than 25 kilograms (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material (see 49 CFR 173.50) in a motor vehicle, rail car, or freight container.
  3. More than one liter (1.06 quarts) per package of a material extremely toxic by inhalation (that is, a “material poisonous by inhalation” that meets the criteria for “hazard zone A” as specified in 49 CFR 173.116(a) for gases or 173.133(a) for liquids).
  4. A hazardous material (including hazardous wastes) in a bulk packaging having a capacity equal to or greater than 13,248 liters (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids. Please note that a person who offers or transports a hazardous material in a bulk packaging with a capacity greater than 3,500 gallons or 468 cubic feet must register, even if placards are not required (for example, a Class 9 material).
  5. A shipment in other than a bulk packaging of 2,268 kilograms (5,000 pounds) gross weight or more of one class of hazardous materials (including hazardous wastes) for which placarding of a vehicle, rail car, or freight container is required for that class.
  6. A quantity of hazardous material that requires placarding. The placarding requirements are set forth in 49 CFR 172 Subpart F and summarized on
    our website. Note that the transportation of any quantity of a hazardous material, other than Division 6.2 and Class 9 materials, in a bulk packaging requires placarding and therefore registration. This includes residues that remain in an un-purged tank truck or rail tank car. Persons who return such packagings are required to register as offerors of a placarded shipment of hazardous materials.

What does registration cost for 2020-2021?

Small business and non profits – $275

Not small businesses – $2600

How to register?

PHMSA has put together this guide to answer your registration questions.

Register online here.

Regulations regarding PHMSA registration are found in 49 CFR 107.601-107.620.

If you have any questions regarding hazardous materials registration, please let me know. We will be happy to assist you with your hazmat questions. Contact me at hello@hazmathelp.com or (704) 573-0955.

Christine Holloway-Clare is the Vice President of Safety Specialists, Inc. She has been assisting customers comply with the hazardous materials regulations for over 20 years.

Safety Specialists, Inc. offers a wide range of hazardous materials transportation training and consulting options. Online training is available. Monthly online classes for DOT, IATA and IMDG available. Join one today.

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PHMSA notice on shipping papers

On April 10, 2020, PHMSA issued the following on existing options for hazmat shipping papers.

“Notice Highlighting Existing Options Related to Hazardous Materials Shipping

Papers and Social Distancing during the COVID-19 Public Health Emergency

The U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has received inquiries regarding the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the exchange of shipping

papers. Many of these inquiries have focused on the need to maintain social distancing between shippers and carriers.

Under the HMR, no physical contact between parties is required for the purposes of shipping papers. Shippers and carriers may therefore meet all requirements for hazardous materials

shipping papers and maintain necessary social distancing. Shippingpapersmaybe exchanged, for example, by physically attaching the document to a clipboard and placing it on a table and stepping away while the paper is signed, or sending the document via email or other means of electronic transmission.

Concerns have specifically been raised about the shipper’s certification statement. Section 172.204(d) states that the shipper’s certification on a shipping paper: ”…[m]ust be legibly

signed by a principal, officer, partner, or employee of the shipper or his agent; and … [m]ay be legibly signed manually, by typewriter; or by other mechanical means.” A shipper may ask a person to sign on its behalf, i.e., to entei’the shipper’s name as the signature for the shipper’s certification on the shipping paper. The request may be made verbally or in writing, and may be electronically transmitted (e.g., text message or email).

Using the methods outlined above, PHMSA believes carriers and shippers may satisfy the safety requirements of the HMR while maintaining appropriate social distancing during the COVID-19 public health emergency.”

A copy of the notice can be found here.

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Shipping Hand Sanitizer? PHMSA is offering some temporary relief

Due to COVID-19, more companies are offering alcohol based hand sanitizer for transportation. PHMSA has issued a notice offering temporary relief from some of the hazardous materials regulations for products that are being produced under the FDA’s guidance.

This relief has been extended until October 31, 2020. The extension notice can be found here.

PHMSA issued temporary relief for hand sanitizer shipped in the US

This relief

  • applies to highway transportation only.
  • will expire when the health emergency is over or 3 months from the issue date (April 2, 2020), whichever is sooner. EXTENDED UNTIL OCT. 31, 2020. NOTICE FOUND HERE.
  • states that PHMSA will not take enforcement action for violations of the hazardous materials regulations if the procedures in the notice are followed.

The required provisions will depend on the amount to be shipped. See the provision summaries below.

PACKAGING UP TO 8 GALLONS of hand sanitizer containing ethyl alcohol or isopropyl alcohol with an alcohol content not exceed 80%. The requirements to be followed are based on the container size of the hand sanitizer. If 1 gallon or less, refer to number 1 below. Over 1 gallon, refer to number 2 below.

  1. Combination packaging – inner packaging up to 1 gallon each and outer packaging cannot exceed 8 gallons total (e.g. 8 x 1 gallon packages)
    • PACKAGING REQUIREMENTS
      • Leak tight packagings must be securely closed. Protected against damage and secured against shifting.
      • Package closure in an upright orientation
    • MARKING ON OUTER PACKAGE AND OVERPACKS
      • Company name
      • The words “Sanitizer – Contains Ethyl Alcohol” or “Sanitizer – Contains Isopropyl Alcohol”
    • NOT REQUIRED TO:
      • apply flammable liquid hazard class label
      • apply any additional marking(s)
      • placard vehicle
      • prepare hazmat documentation
  2. Packagings – exceeding 1 gallon capacity
    • PACKAGING REQUIREMENTS
      • Packages are overpacked in crates, boxes, cages, carts, etc.
      • Secured in transport vehicle to protect against damage, leakage and movement.
      • Package closure in an upright orientation
    • MARKING ON PACKAGE AND OVERPACKS
      • Company name
      • The words “Sanitizer – Contains Ethyl Alcohol” or “Sanitizer – Contains Isopropyl Alcohol”
    • NOT REQUIRED TO:
      • apply flammable liquid hazard class label
      • apply any additional marking(s)
      • placard vehicle
      • prepare hazmat documentation

PACKAGING OVER 8 GALLONS of hand sanitizer containing ethyl alcohol or isopropyl alcohol with an alcohol content not exceed 80%.

  1. Packagings – exceeding 8 gallon capacity but not more than 119 gallons
    • PACKAGING REQUIREMENTS
      • DOT or UN specification packaging is required.
        • Must be X or Y performance level packaging
      • Leak tight packagings must be securely closed.
      • Protected against damage and secured against shifting.
    • LABELING
      • Class 3 flammable liquid label must be on all packages
    • DOCUMENTATION
      • Bill of lading must include the following:
        • Basic description “UN1987, Alcohols, n.o.s., Class 3, PG II”
        • Number, type and capacity of packages offered (e.g. 25 drums – 119 gallons ea.)
    • EMERGENCY RESPONSE GUIDE 127 must accompany the shipment
      • Click here for a copy of Guide 127
    • PLACARDS – FLAMMABLE LIQUID
      • Required if aggregate gross quantity in vehicle exceeds 1001 lbs.
    • PHMSA REGISTRATION not required
    • EMPLOYEE TRAINING
      • Required for all shippers and carriers of this materials
      • PHMSA has provided training materials
        • Presentation slides from PHMSA can be downloaded here
        • Craft Spirits Assoc. Webinar on shipping alcohol based hand sanitizers can be found here. This is a 50 minutes webinar.
    • All motor carriers must comply with 49 CFR 177.804

A copy of this notice from PHMSA can be found here.

If you have any questions on shipping hand sanitizer or any other hazardous materials, please let us know. Email us at hello@hazmathelp.com or call us (704) 573-0955.

Stay safe and healthy!

Christine Holloway-Clare is the Vice President of Safety Specialists, Inc. She has been assisting customers comply with the hazardous materials regulations for over 20 years.

Safety Specialists, Inc. offers a wide range of hazardous materials transportation training and consulting options. Online training is available. Monthly online classes for DOT, IATA and IMDG available. Join one today.