Does transporting a hazardous material to a job site or work area always have to be such a headache?
Absolutely not. Companies are finding relief from the never-ending nightmare of complying with the Hazardous Materials Regulations (HMR) with three simple words: materials of trade.
â€œNot subject to any other requirements of this subchapterâ€ is a phrase seldom found in the HMR. It is one that quickens the pulse of anyone who has ever had to spend time poring over paragraph after paragraph and page after page of hazmat regulations.
To clarify, the phrase means not having to comply with the requirements of Subchapter C of 49 CFR. Thatâ€™s not everything as far as the regulations are concerned, but itâ€™s close. The majority of what needs to be done, compliance-wise, when transporting a hazardous material, is found in that subchapter.
Youâ€™ll find the very same phrase in the first paragraph of 49 CFR 173.6. If you follow the provisions contained within that one specific section, youâ€™re good to go when transporting smaller amounts of certain hazardous materials.
Itâ€™s like having a â€œGet Out Of Jail Freeâ€ card when transporting hazmat.
There has to be a catch somewhere. Right?
Not really. The materials of trade exceptions arenâ€™t going to help companies that ship or transport large amounts of hazmat day in and day out. They are not designed for those who make their living shipping or hauling hazmat. However, the exceptions can help many companies that arenâ€™t typical hazmat haulers.
The bottom line is certain hazardous materials transported in smaller quantities do not present the hazards in transportation associated with hazmat transportation in general.
Each hazmat must be either packaged in the manufacturerâ€™s original package or one of equal strength. Packages have to be leak-tight for liquids and gases, and sift-proof for solids. They must be securely closed, secured against shifting and protected against damage.
If the hazmat is a high hazard (Packing Group I), the maximum amount allowed in one package is one pound or one pint. In most cases, a hazmat package with medium or lower hazards (Packing Group II or III) may contain a maximum amount of 66 pounds or eight gallons.
Cylinders containing a Division 2.1 or 2.2 gas may not weigh more than 220 pounds each. There are no package limits for ORM-D (consumer commodities), which account for a large share of the hazmat transported by contractors, builders, plumbers, welders and so on.
Except for tanks containing diluted mixtures of a Class 9 material, the maximum limit is 440 pounds on any motor vehicle. If you need to transport more than that, why not make two trips or take two vehicles? It makes good sense. Why get involved with the hazmat regulations when it isnâ€™t necessary?
Make a copy of that particular section (about a page) and carry it in the vehicle transporting the hazmat. It never hurts to have a â€œGet Out Of Jail Freeâ€ card along, just in case.