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. With the onset of OSHA HazCom2012 and WHMIS 2015, many companies are opting to follow the rules in those standards for workplace labeling rather than relying on HMIS information.

Hazard Class Label for Lithium Battery

Q. Does my shipment of UN3481 under IATA need a Class 9 hazard label and the lithium battery handling label? The batteries inside the device have a watt-hour rating of 30.

A. With that watt-hour rating you meet the criteria for Section II under Packing Instruction 967. As an excepted battery inside equipment the only thing needed on the outside is the lithium battery handling label. Please note that “label” will no longer be allowed starting Jan 1, 2019.