Environmental Health & Safety Compliance Blog

Understanding “UN” Markings

Posted by Rebecca McDaniel on Sep 1, 2010 7:35:00 AM

By Amanda Mendonza, Technical Services Representative

So you finally got your RCRA and DOT training and you’re ready to start shipping waste. You learned about appropriate container labeling and how to properly fill out your uniform hazardous waste manifest. One important part of your training should have been making sure your chemical waste is contained in a “specification” packaging for the material you are shipping. If you are shipping a DOT-regulated hazardous material, then your drum will have to be “UN-specification” (that’s UN as in United Nations). This means that the drum has been tested to international standards of integrity, such as drop and pressure testing. You can check whether your drum is UN-specification by the UN test marking located on the side or top of the drum. It will have a series of codes in the following configuration:

describe the image1H1/Y1.8/150/05/USA/M824 /1.1 mm


Here is how you decode the series:

1H1: Is a packaging identification code designating the container type, material of construction, and in some cases, a characteristic. In this case the notation is saying this is a closed top plastic drum.

Y: Indicates which of the three performance standards has been met which tells the filler which packing group materials (PG I, II, or III) are allowed. X = OK for PG I, II, or III, Y= OK for PG II or III, Z = PG III only

1.8: Designates the maximum specific gravity of the liquid chemical suitable for this drum. In this case, the notation is saying this drum is able to withstand the weight of a liquid with a density up to 1.8 g/cm3. Non- leak proof containers will have a maximum gross mass in kilograms at this spot in the marking.

150: Is the hydrostatic pressure test in kPa. Non-leak proof containers will have an “S” at this spot in the marking. Shippers must select materials with vapor pressures that are not too high- the pressure test marking is used as part of that calculation (see 49 CFR 173.24a(b)(4) for how to calculate).

05: 2005 Production year

USA: Manufactured in the U.S.

M824: This spot is used to indicate, either by name and address, or by the use of a symbol, what party performed the UN- protocol testing.

1.1 mm: On many drums, the minimum thickness of the material of construction is indicated in millimeters (this is required in some cases for the container to be eligible for reuse).

On reconditioned drums, you may also see an abbreviated version of the full series, such as: 1H2/Y25/S

And remember, all UN-specification drums come with a set of closure instructions by the manufacturer to which you much precisely follow and retain a copy of for a period of 1 year after a package is offered for transport.

Tags: DOT

Changes to DOT HazMat Services Security

Posted by Rebecca McDaniel on Mar 29, 2010 12:54:00 PM

By Doug Graham, CHMM Sr. Compliance Advisor & Training Manager

The U.S. Department of Transportation (DOT) is modifying current security plan requirements applicable to shippers and carriers of hazardous material.

Based on an evaluation of the security threats associated with specific types and quantities of hazardous materials, the final rule narrows the list of materials subject to security plan requirements. The final rule also clarifies certain requirements related to security plan components, training, and documentation.

In a qualitative risk evaluation, DOT considered the following factors when deciding how the new security planning requirements would better address actual terrorism threats: (1) Physical and chemical properties of the material or class of materials and how those properties could contribute to a security incident; (2) quantities shipped and mode of transport; (3) past terrorist use; (4) potential use; and (5) availability.

In this "new look" at which materials pose significant risk, DOT explained that , "One of the most significant security vulnerabilities involves the potential for an individual or group to take control of a conveyance containing a high-risk material and move it to a site where the material could cause maximum physical or psychological damage. For some hazardous materials, the primary security threat involves theft or highjacking of raw materials for use in developing explosive devices or weapons".

So, based upon this fresh analysis and the need for clarification to the original rule, the following is a summary of the regulatory changes to the security planning rule that are slated to go into effect on October 1 of 2010:

  • Firstly, the list of materials being either offered or transported, which would trigger the requirement for developing a security plan has changed. The list, found in 49 CFR 172.800(b) currently identifies seven categories, including placardable quantities. The new list identifies sixteen very specific categories of hazardous materials, most of which have threshold quantities.
  • Secondly, the required components of a written security plan under 49 CFR 172.802 have been clarified and expanded. Hi-lights include:
  1. clarification that the plan must address risks associated only to those materials identified in 172.800(b);
  2. there must be a senior management official identified who is responsible for development and implementation of the plan;
  3. the plan must identify security duties for each position or department responsible for implementing all or part of the plan;
  4. the plan must describe the process for notifying employees when plan elements are to be implemented; and
  5. the plan must be in writing, retained (paper or electronic), available to employees responsible for implementing it, updated as necessary, reviewed annually, and made available to the DOT for inspection, upon request.
  • And lastly, the security training requirements under 172.704 have been clarified.

In summary, it is anticipated that many employers who currently require security plans solely due to offering placardable quantities of common hazardous material will no longer need them. Additionally, those who will still require security plans under the new rule will need to make major revisions to their plans, procedures, and recordkeeping.

To see the complete revised rule change as published in the March 9, 2010 Federal Register, go to: http://edocket.access.gpo.gov/2010/2010-4778.htm

Tags: DOT, 49 CFR

Regulatory Compliance: New Rules for Lithium Batteries

Posted by Rebecca McDaniel on Jan 14, 2010 9:34:00 AM

Doug Graham, CHMM Sr. Compliance Advisor & Training Manager

Yes, they’re at it again! Just when you thought you knew how to ship lithium batteries, DOT has thrown in yet another potential rule change.

Currently, there are exceptions for certain “small” lithium metal (primary) and lithium ion (rechargeable) batteries, wherein the DOT allows those batteries to be shipped under a special provision. If the batteries (including those in equipment) meet the requirements described in Special Provision 188 of 49 CFR 172.102, they need not comply with the entire scope of the hazardous materials regulations. DOT defines the maximum size of the batteries applicable to this provision based upon the amount of lithium within each cell and the total within each battery. The batteries that fall within this small-sized range are those we typically find inside cell phones, cameras, and laptop computers, and have power ratings under roughly 100 Watt-hours (Wh).

In a press release on January 8, 2010, the DOT is proposing to remove those exceptions for small lithium batteries, effectively making them fully regulated Class 9 hazardous materials like their medium and large-sized counterparts. The justification for the proposed rule change was explained by House Transportation and Infrastructure Chairman Jim Oberstar this way, "Under existing regulations, a flight crew may not be made aware of a pallet containing thousands of lithium batteries on board the aircraft, yet a five-pound package of flammable paint or dry ice would be subject to the full scope of the regulations. That makes little sense. . .”

To follow these developments regarding lithium battery shipping issues, and other emerging rules regarding DOT hazardous materials, log onto www.phmsa.dot.gov/hazmat . To view the proposed rule change (docket HM-224F) as published in the Federal Register on January 11, 2010, click on the following link: http://edocket.access.gpo.gov/2010/2010-281.htm. So. . . . . .keep your ear to the ground, if history’s any indicator, there’s sure to be more to come.

Tags: Hazardous Materials, DOT, Lithium Batteries, Training, Regulations, PHMSA, Trainings

Lithium Battery EH&S Safety Concerns

Posted by Rebecca McDaniel on Dec 14, 2009 9:11:00 AM

By Doug Graham, Senior Environmental Compliance Advisor

Most shippers and carriers are now aware of several regulatory changes that have effectively tightened up the shipping requirements for both lithium metal and lithium ion batteries. Both the US Department of Transportation and the International Air Transport Association have made significant revisions to the rules in both 2008 and 2009. 

Packaging Lithium Batteries per updated DOT Regulations

Guidelines for New DOT Regulations Regarding Batteries sent for Recycling

What’s this all about?

Here are a few interesting facts and statistics raised during a November 19, 2009 hearing of the U.S. House of Representatives Subcommittee on Railroads, Pipelines and Hazardous materials:

  • The Federal Aviation Administration (FAA) gathered information on 90 hazardous materials incidents occurring from 1991 to 2008. That data indicated that 27 percent of these incidents involved lithium batteries.
  • The vast majority of those lithium battery incidents (73%) resulted from either internal or external short-circuiting; 12% from charging or discharging; and 6% from activation of devices containing lithium batteries. The balance of the incidents resulted from either malfunctions or improper handling.
  • FAA testing has indicated that current aircraft cargo fire suppression system would not be capable of suppressing a fire if a shipment of metal lithium batteries were ignited in flight.
  • The National Transportation Safety Board (NTSB) investigated a February 7, 2006 incident at the Philadelphia International Airport in which a fire – suspected to have been caused by lithium batteries – destroyed a United Parcel Service cargo aircraft and most of its cargo.
  • That incident lead to the NTSB making five recommendations to the DOT Pipeline and Hazardous Materials Safety Administration.

In light of this increased awareness and dynamic rule-making environment, offerors and transporters are well-advised to check and double check the most recent requirements before getting lithium batteries moving over the road, water, or especially, through the air.

Tags: Hazardous Materials, DOT, IATA, Lithium Batteries

Proactive Chemical Management

Posted by Rebecca McDaniel on Dec 8, 2009 10:27:00 AM

By Greg Rosinski, Chemist II

Walking through the laboratories of colleges and universities will result in seeing a lot of unused chemicals that are prior circa 1980. Typically the chemicals are pushed to the back of the chemical storage cabinet until the professor retires. In order to decrease the potential exposure these chemicals could create it is important for the Environmental Health and Safety (EH&S) department to monitor the amount of these chemicals remaining. Recently, a local university had a professor retire from a career of over 50 years of teaching in the same lab. This professor had a refrigerator full of temperature sensitive chemicals that he kept adding to over the years without properly disposing of them. Murphy’s Law played out in this circumstance when a storm happened on the weekend causing a power outage. The school’s generators also were struck causing the refrigerator to shut off, and increase in temperatures beyond the allowable range for the chemicals. The chemicals reacted causing the containers to fail, and spill throughout the refrigerator. On Monday when the professor went to open the refrigerator to start his lab the fumes were nauseating, and forced the EH&S department to call Triumvirate Environmental Inc. to properly dispose of the chemicals. The EH&S then had to make a phone call to have the refrigerator properly decontaminated. The cost to the university in bills and the inconvenience of shutting down the lab has made the EH&S director proactive in disposing of unused chemicals. The result of proper management of aged chemicals has reduced their average spending on disposal, and the occurrence of spills or other incidents. Properly managing chemicals involves spending time in labs, and looking outside of the normal areas. This will help to identify chemicals that are no longer in use. The cost of spills costs more than proactively managing a hazardous waste program. A good place to start looking for temperature sensitive chemicals (not an all inclusive list) is the Department of Transportation (DOT). The DOT’s list can be found in 49 CFR 173.224 for self reactive materials, and 49 CFR 173.225 for organic peroxides. These two types of chemicals are known to become unstable with age.

Tags: Environmental Health and Safety, EHS, DOT, Department of Transportation, Chemicals, 49 CFR, Chemical Management

Compliance with the DOT HAZMAT Shipping Regulations

Posted by Rebecca McDaniel on Dec 2, 2009 7:33:00 AM

By Doug Graham, CHMM

The DOT hazardous materials regulations are a lengthy, complex set of rules with wide-sweeping applicability in many facilities. Investigating all the employees, vendors, materials, and shipment types involving hazmats can be challenging. To make matters worse, shipments may be originating from numerous departments, not necessarily immediately obvious to EH&S staff. Here are a few examples, I’ve heard many times over the years- “I didn’t know the lab was shipping dry ice by air”, “the engineering department has their own FedEx account?”, “Materials Management sent back hazardous chemicals to the supplier in a regular box?”, and my personal favorite- “who authorized him to sign hazardous waste manifests?”.

Here are 10 steps one can take to get a handle on DOT hazardous materials compliance-

1. Identify all potentially-regulated hazardous materials (hazardous wastes, medical /biological wastes, biological products and specimens, dry ice, radioactive materials, and hazardous chemicals (e.g., poisons, corrosives, gases, oxidizers, and flammables) that could potentially be shipped from each department.

2. Identify the modes of transport and carriers and the regulations applicable to each (e.g., 49 CFR for ground and UPS domestic air; IATA for FedEx Express; IMDG for international marine).

3. Identify all employees who have responsibilities related to preparing hazardous materials for transport (“hazmat employees”).

4. Develop training program(s) for those employees addressing general awareness, function-specific, and security issues, including training specific to 49 CFR, IATA, and IMDG, when applicable.

5. Train new hazmat employees within 90 days and retrain every 36 months.

6. Create shipping procedures for regularly-offered hazardous materials, and an auditing system to check shipments prepared by contractors, such as hazardous waste profiles, manifests, and labels prepared by waste vendors.

7. Keep up to date by reviewing regulatory changes on a yearly basis (49 CFR effective each Oct. 1, IATA effective each Jan. 1).

8. Maintain records and administrative programs, including annual registration, security planning, training records, past shipping papers, incident reports, and current regulations.

9. Know when and where to ask for help, e.g., Hazmat hotline, consultants.

10. Self-audit on a regular basis, be prepared for a regulatory or corporate audit, and reinforce through training, review and accountability.

Tags: Hazardous, Hazardous Materials, EHS, DOT, IATA, 49 CFR, Hazardous Chemicals