Module 1: Regulations - International Association of Fire … Module 01 Student Text.pdf · · 2007-04-04Quiz at the beginning of this module. ... Safety and Health Act? A. OSHA

Module 1: Regulations 1-1

Student Text IAFF Training for Hazardous Materials: Technician©

Module 1:

Regulations

1-2 Module 1: Regulations

IAFF Training for Hazardous Materials: Technician© Student Text



Module 1: Regulations

Module Description

This module explains the federal regulations governing the use, storage, and transport of hazard-ous materials in the U.S.

Prerequisites

• Students should have completed a hazardous materials operations level training program.• Students should be familiar with federal, state, and local agencies governing hazardous

materials response.



Objectives

Upon completion of this module, participants will be able to:

• State the purpose of hazardous materials regulations.

• Define a hazardous material.

• List and describe nine hazard classes and the respective hazarddivisions.

• Distinguish among packing groups I, II, and III.

• List four hazard zones.

• Identify a hazardous material by its hazard class and division, packinggroup, and hazard zone, using analytical data.

• Label packages using primary and subsidiary labels.

• Differentiate between technical and generic shipping names.

• Evaluate hazardous material shipping papers.

• List special provisions applicable to hazardous material shipments.

• Describe packaging requirements found in hazardous material regula-tions.

• Identify symbols used in the Hazardous Materials Table.

• Evaluate primary and subsidiary hazards using shipping names,shipping papers, and the precedence table.

• Correctly identify DOT hazard labels for hazmat shipments.• Use primary and subsidiary hazard labels.• List the five components of DOT marking requirements.• Interpret a packaging label.• Define and distinguish between labels and markings.• Locate the segregation requirements for three pairs of hazard classes on

the segregation table.

• Describe training requirements and employees covered by any of the fol-lowing OSHA standards 1910.1200, 1910.120, 1910.134 - 138,1910.1030, 1910.146.

• List the key elements of 1910.120.• List the 5 levels of training described in paragraph (Q) of 29 CFR

1910.120.

ObjectivesNFPA

StandardsOSHA

Standards

NFPA 4721-1.1 & 1-1.2NFPA 4721-2 & 2-2.1.1NFPA 4722-2.1.2 % 2-2.1.3NFPA 4721-2NFPA 4723-4.1.1 & 3-4.1.2NFPA 4723-2.1.2

NFPA 4723-2.2NFPA 4723-2.2NFPA 4724-2 thru 4-6.3.10NFPA 4721-2NFPA 4724-3.3 (a) 2NFPA 4724-3.3 (a) 2

NFPA 4722-2.1.7 thru2-2.19, 3-2.1.3.2,4-2.1.2.1(applies to all ofthese)

NFPA 4724-1.1

29CFR 1910.120(q) (6) (iii)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (F)29CFR 1910.120(q) (6) (iii) (B)(E) (F)

29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)29CFR 1910.120(q) (6) (iii) (B)

29CFR 1910.120(q) (6) (iii) (B)

29CFR 1910.120(q)29CFR 1910.120(q)



Instructor Preparation

Instructors should have a basic knowledge of OSHA, EPA, and DOT regulations that coverhazardous materials and hazardous waste. Instructors should also be familiar with the use,transportation, and storage of those materials, and the common identification methods used inindustry as well as emergency response.

Select three to five pages from the Hazardous Materials Table (49 CFR 172.101) and makecopies for the students. This table is reproduced on page 19. Plan on giving the PrerequisiteQuiz at the beginning of this module. If any students fail to answer at least half the questionscorrectly, they should be directed to read Training for Hazardous Materials Response: YourRights and Responsibilities and Unit 3 of Hazardous Materials Training for First Responders.Both programs are available through the IAFF’s Hazardous Materials Department.

Equipment/Supplies

1996 North American Emergency Response GuidebookTitle 49 CFR 171 - 178 (optional)Title 29 CFR 1910 series (optional)DOT placards and labels for all classes and divisionsSeveral examples of HMIS and NFPA labels (completed)Hazardous Waste LabelNon bulk container for any hazardous material (with label and markings) and accompanyingshipping papersHazardous materials (Examples of common household and commercial products that can befound on the Hazardous Materials Table 49 CFR172.10.) Products may include:• Pesticides• Herbicides• Bleach• Lye• Solvents• Paints and paint products• Gasoline• Propane tank for outdoor grill• Radioactive lantern mantelsNIOSH Pocket Guide to Chemical HazardsSupplies for Application Exercise (at end of module before appendices)Transparencies and overhead transparency projectorVCR and Videotape: Colorado Springs Uranium Ore Spill

Approximate Length

This module requires five to seven hours to complete.





Module 1Prerequisite Quiz

1. Which of the following statements best describes the standards set by the OccupationalSafety and Health Act?A. OSHA standards apply primarily to emergency respondersB. OSHA standards apply primarily to hazardous waste sitesC. OSHA standards apply primarily to local, state, and federal workersD. OSHA standards apply to all workplaces

2. Which of the following statements best describes the regulations set by the Environmen-tal Protection Agency?A. EPA regulations apply primarily to emergency responseB. EPA regulations apply primarily to hazardous wastesC. EPA regulations apply primarily to local, state, and federal work sitesD. EPA regulations apply primarily to privately owned work sites

3. Which of the following organizations issues mandatory standards?A. National Institute for Occupational Safety and Health (NIOSH)B. National Fire Protection Association (NFPA)C. Occupational Safety and Health Administration (OSHA)D. Both A and C

4. The OSHA standard that protects workers in hazardous waste operations and emergencyresponse is:A. 29 CFR 1910.120B. 29 CFR 1400zC. 49 CFR Subchapter CD. 49 CFR 172.101

5. OSHA’s Hazard Communication Standard is:A. An employer right-to-know lawB. An emergency worker right-to-know lawC. A community right-to-know lawD. A worker right-to-know law

6. Which of the following organizations issues hazard classes and divisions?A. Department of Transportation (DOT)B. Department of Energy (DOE)C. National Institute for Occupational Safety and Health (NIOSH)D. National Institute of Environmental Health Sciences (NIEHS)



7. Un identification numbers indicate that a chemical may be shipped:A. Only within North AmericaB. Only within the United StatesC. Only within the country of originD. Internationally

8. Hazardous materials that must always be placarded, regardless of quantity, are:A. Table 1 materialsB. Table 2 materialsC. Other Regulated Materials (ORMs)D. Flammable chemicals

9. Title 49 in the Code of Federal Regulations includes all:A. EPA RegulationsB. OSHA RegulationsC. DOT RegulationsD. None of the above

10. The Superfund Amendment and Reauthorization Act is administered by:A. EPAB. OSHAC. DOTD. DOE



IntroductionQuestions

1. Is your state covered by OSHA or EPA regulations?

2. What is the regulatory number of HAZWOPER?

3. According to DOT, what is an “X” container?

4. The OSHA regulation, 29 CFR 1910.1200 is also knownas what standard?

Governing Agencies

In the U.S. there are several agencies that are involved inregulating chemicals and hazardous wastes. The keyfederal agencies are the Department of Transportation(DOT), which regulates hazardous materials in transit; theOccupational Safety and Health Administration (OSHA),which regulates hazardous materials in the workplace; andthe Environmental Protection Agency (EPA), which covershazardous waste. Some state and local jurisdictions haveadditional regulatory agencies. It is your responsibility toknow your state and local regulations.

These federal agencies communicate their regulations in theCode of Federal Regulations (CFR). The CFR is a singleor multiple volume set of regulations which is publishedannually. Each CFR is organized by a numbering system.The title of a CFR identifies the agency that wrote theregulations.



Additionally, the federal government prints the FederalRegister every business day. The Federal Register containschanges to existing regulations, meeting announcements,notice of proposed regulations, and the final version ofregulations prior to publication in their respective CFR.

State Regulatory Agencies

The DOT and EPA turn over the regulation of hazardousmaterials and wastes to the state regulatory agency only ifthe state program meets or exceeds EPA requirements.Research your state requirements to be sure your actionsreflect these laws.

Federal Department Title Number

Department of Transportation 49

Environmental Protection Agency 40

Department of Labor (OSHA) 29



CFR Structure

The CFR is organized using a numerical system. Eachvolume is subdivided using the following hierarchy:

Title Titles are written in numbers (usuallywith two digits) in front of theacronym CFR. [example, 40 CFR]

Chapter Chapter numbers are written inroman numerals following the wordChapter after the acronym CFR. [example, 40 CFR Chapter I]

Part Parts are written in numbers. Partnumbers are assigned numericallybeginning with 1 and continuinguntil the regulation is finished (ashigh as 1499). [example, 261]

Subpart Subparts are written in capital lettersA through Z and continuing AAthrough ZZ. [example, C]

Section Sections are written as numbersimmediately following the decimalpoint. Section numbers begin withthe number 1 and continue numeri-cally until the part is finished.[example, .7]

Paragraph Paragraphs are written using smallletters beginning with a. Paragraphdesignations are placed inside paren-theses. [example, (a)]

Subparagraphs Subparagraphs are written as smallcase roman numbers. Subparagraphnumbers are also placed insideparentheses and will always follow aparagraph number.



As indicated earlier, each title number is assigned based onthe department that writes the regulation. Every title issubdivided into chapters, parts, sections, and paragraphs.For example, 29 CFR 1910.120(q)(3)(iii) breaks down asfollows:

Each of the three federal agencies discussed in this modulerequires some type of emergency response/hazardousmaterials contingency plan. These plans can serve as abasis for pre-incident plans for fixed facilities as well assome transportation routes. The basic recognition andidentification clues, coupled with facility plans, give you atremendous amount of valuable information.

Title CFR Chapter Part Subpart Section (Paragraph) (Paragraph #) (Subparagraph)

29 CFR I 1910 . 120 (q) (3) (iii)



Department ofTransportation

Questions

Refer to the Straight Bill of Lading on the following page toanswer the following questions:

1. What does the “RQ” before acetone mean?

2. What is the primary hazard of the cargo?

3. What does Packing Group II signify?

The Department of Transportation (DOT) regulates thetransportation of hazardous materials, including hazardouswastes. The purpose of the hazardous materials regulationsis to identify materials that are dangerous during transporta-tion and to communicate the dangers and hazards associ-ated with such materials. In the Hazardous MaterialsTransportation Uniform Safety Act (HMTUSA) of 1990,the DOT mandated that hazardous materials employersmust provide training for all hazardous materials employ-ees. A hazardous materials employer is defined in 49CFR 171.8 as

“a person who uses one or more of its employees inconnection with: transporting hazardous materials incommerce; causing hazardous materials to be trans-ported or shipped in commerce; or representing, mark-ing, certifying, selling, offering, reconditioning, test-ing, repairing, or modifying containers, drums, orpackagings as qualified for use in the transportationof hazardous materials.”

A hazardous materials employee is “any employee who directly affects hazardous mate-rial transportation safety through involvement in pack-aging, transport, manifesting, labeling, maintenance,etc.”

A hazardous materials employee is also“a person who is employed by a hazardous materials



employer and who in the course of employment di-rectly affects hazardous materials transportationsafety.”

Job functions under this requirement are as follows:

• Commercial drivers• Loaders and handlers of hazardous materials• Hazardous materials cargo trailer and truck maintenance

personnel• Dispatchers• Administrative personnel who prepare hazardous

materials shipping papers• Personnel who affect hazardous materials transportation

through packaging, labeling, and marking• Safety supervisors and officers

On May 15, 1992, the Research and Special ProgramsAdministration issued a final rule called HM-126F, Trainingfor Safe Transportation of Hazardous Materials, thusamending the Hazardous Materials Transportation UniformSafety Act of 1990. This final rule amended the hazardousmaterials regulations in order to enhance the trainingrequirements for persons involved in the transportation ofhazardous materials. Its purpose is to ensure that eachhazardous materials employer trains employees on the safeloading, unloading, handling, storing, and transporting ofhazardous materials and on emergency preparedness inresponse to accidents or incidents involving hazardousmaterials. Specifics concerning DOT training requirementsapplicable to the hazardous materials employee are de-scribed on the following pages.

In addition, the Performance-Oriented Packaging Standards(POPS), also referred to as HM-181, were promulgated.POPS standards are found in 49 CFR Subchapter C andbring the United States into compliance with internationalhazardous materials shipping regulations. UN Guidelinesrequire all shipments to be:• Packaged in United Nations (UN)-specified containers

• Classified, named, marked, placarded, and labeled inaccordance with the Hazardous Materials Table in 49CFR 172.101



The major purpose of POPS is to identify materials thatmay be hazardous during transportation and to communi-cate the hazards of such materials adequately. The DOTendorsed POPS for several reasons, including:

• To transport hazardous materials in accordance with UNguidelines so that a container can be shipped all over theworld with the same markings

• To simplify the hazardous materials transportation regu-lations

• To reduce the quantity of DOT regulations concerninghazardous materials

• To limit the quantity of exemptions issued by DOT

Transporters and packaging manufacturers are now re-quired to adopt POPS. All packagings must meet perfor-mance-based criteria.



Compliance Schedule

To facilitate the transition from domestic to internationalhazardous materials transportation regulations occursmoothly, the DOT has spread compliance dates for POPSover a ten year period. See 49 CFR 171 for details.

DATE COMPLIANCE SCHEDULE

October 1, 1991 Explosives must be shipped in accordance with POPS.Poison by inhalation (PIH) gases must be shipped in accor-dance with POPS.

October 1, 1992 All PIH paperwork and placarding shipments must complywith POPS.

October 1, 1993 All hazardous materials communication and shipping papersmust comply with POPS.PIH shipments must be transported in accordance withPOPS.Shippers must use the Segregation and Separation Table in49 CFR 177.848.

October 1, 1994 All new packagings must be manufactured in accordance withPOPS.Shippers can still use “old” packagings.Infectious substances must be described on shipping papersand packaged in accordance with POPS.

October 1, 1996 New Generic Shipping Names in HM-215AHazardous Materials Table.Shippers MUST use POPS packagings.

October 1, 2001 HM-181 placards must be displayed for domestic shipments.



Definition of aHazardous Material

A hazardous material is defined by the DOT“to be capable of posing an unreasonable risk tohealth, safety, and property when transported.”

Materials designated “hazardous” by the DOT can be foundin the Hazardous Materials Table, 49 CFR 172.101.Several common chemicals are included in the sample tableon page19. Materials are listed in alphabetical orderaccording to their proper shipping names (Column 2).Materials not listed in the Hazardous Material Table maystill be hazardous if the material exhibits a hazard as de-fined by a DOT hazard class.

For example, paint thinner is not listed in the HazardousMaterials Table, yet its flash point is less than 60°C and itsinitial boiling point is less than 35°C. Therefore, paintthinner meets the DOT definition of a flammable liquidmaterial and must be transported as a hazardous material.

Identifying Hazards

Hazardous materials regulations specify ways to communi-cate the hazards associated with a material. There are fourways to communicate such hazards. These include:

Labels Every hazardous material is required to havea label(s). The label usually corresponds toa hazard class and are listed in the Hazard-ous Materials Table Column 6.

Markings A hazardous material package is required tobe marked with its proper shipping nameand identification number, as well as anyapplicable technical names. Additionalmarking requirements can be found in 49CFR 172.301.

Placards Placards are large versions of labels, placedon transport vehicles and bulk containers.



Shipping PapersShipping papers are intended to accuratelydescribe the hazardous material beingshipped, including its possible hazards.Shipping papers also identify all partiesassociated with the material.

Hazardous MaterialsRegulations

Hazardous material regulations are found in Title 49 of theCode of Federal Regulations. Title 49 is written by theU.S. Department of Transportation and only applies tocommercial transport.

Title 49 includes all U.S. DOT regulations, not just hazard-ous material regulations. Hazardous material regulationsare found specifically in Subchapter C, Part 171 through178. DOT Title 49 CFR can be a tremendous aid to re-sponders. In addition to the information which was justcovered for highway transportation, 49 CFR also coverstransportation by air, rail, and water. Information such astank construction material, working pressures, and types ofrelief and control devices can be researched in this CFR.To identify titles, parts, and sections, use the followingguidelines.

49 CFR 172.101(Title) (Part) (Section)

The hazardous material table is found in Title 49 of the Codeof Federal Regulations (CFR), Part 172, Section 101.



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The hazardous material table contains information neces-sary to ship specific hazardous materials. The table is thekey to all of the DOT hazardous material regulations.

Column 1 - Symbols.The following symbols may appear in column #1 of thehazardous materials table: A, W, D, I, and +.

The letter “A” in column 1 indicates restrictions applyduring transportation by aircraft.

The letter “W” in column 1 indicates restrictions applyduring transportation by vessel.

The letter “D” in column 1 indicates that ONLY domestictransportation is permitted.

The letter “I” in column 1 indicates that ONLY interna-tional transportation is permitted.

The “+” fixes the proper shipping name, hazard class andpacking group for that entry without regard to whether thematerial meets the definition of that class or packing groupor meets any other hazard class definition.

Symbols Hazardous Materials Shipping Names

D Accumulators, pressurized pneumaticor hydraulic (containing non-flammable gas)

A Acetaldehyde

Acetone

+ Nitric Acid, Red Fuming

Sulfuric Acids



Column 2 - Hazardous Materials Descriptions and Proper Shipping Name.

Column 2 lists shipping names and descriptions in alpha-betical order. The information in italics is not part of thename/description. Only the non-italicized informationshould be included as the shipping name/description. Inaddition, proper shipping names may be used in eithersingular or plural, capital or lower case letters. Punctuationmarks are not a part of the shipping name/description.

Column 3 - Hazard Class or Division.Column 3 contains numerical information concerning thehazard class/division applicable to the hazardous material.The word “forbidden” may appear in column 3. Never shipa material listed as Forbidden. NOTE: Any reference to aClass 3 material may be modified to read combustibleliquid if the material has a flash point above 100oF andbelow 200oF and the material does not meet the definitionof any other hazard class.

Column 4 - UN or NA Identification Numbers.Column 4 lists identification numbers assigned to eachshipping name. Identification (ID) numbers are 4-digitnumbers beginning with the letters UN (United Nations) orNA (North America). ID numbers beginning with UN maybe transported internationally as well as domestically.Identification numbers beginning with NA may not betransported internationally except to and from Canada. TheID number is a 4-digit number used during emergencyresponse. With the ID numbers, you can use the NorthAmerican Emergency Response Guidebook to locateinformation for spill control and containment.

Hazardous Materials UN/NA ID Numbers Packing GroupsShipping Names 2 4 5

Acetone UN 1090 II

Corrosive Liquid,Acetic, Organic, N.O.S. UN 3265 I, II, III

Methylhydrazine UN 1244 I

Nitric Acid, Red Fuming UN 2032 I

Sulfuric Acid UN 1830 II



Column 5 - Packing Group.

Column 5 lists packing groups assigned to hazardousmaterials. Three packing groups are authorized by the U.S.DOT as: I Great dangerII Moderate dangerIII Minor dangerHowever, hazardous materials in class 2, 7, and ORM-Dwill not have a packing group. Packing groups must alwaysbe communicated using Roman Numerals.

Column 6 - Required Labels.Column 6 specifies required hazard warning labels. Thefirst label shown for each entry is the primary hazard label.Other labels indicated are subsidiary hazard labels and mustnot carry the number in the bottom corner.

Column 7 - Special Provisions.Column 7 specifies special provisions which are describedbelow. Special provisions are listed and defined in 49 CFR172.102. The special provision can consist of both a letterand a number. The letter part of the provision identifies theapplicable mode of transportation. The number indicatesthe position in the list. Use the following key to determineapplicability of the special provisions during shipment.

Hazardous Materials Packing Groups Labels RequiredShipping Names 2 5 unless excepted 6

Acetone II Flammable Liquid

Corrosive Liquid, N.O.S. I CorrosiveIIIII

Methylhydrazine I Poison, Flammable Liquid,Corrosive

Nitric Acid, Red Fuming I Corrosive, Oxidizer, Poison

Sulfuric Acid II Corrosive



• A code consisting only of numbers applies to all modesof transportation.

• The letter A applies to transportation by aircraft.• The letter B applies to bulk transportation. It is bulk

transportation if it is NOT non-bulk. See definition ofnon-bulk.

• The letter H applies to highway transportation.• The letter N applies to non-bulk transportation. A non-

bulk package is: a liquid package with a capacity of lessthan 119 gallons or a solid package with a net mass ofless than 400 kg.

• The letter R applies to rail transportation.• The letter T applies to transport of portable tanks.• The letter W applies to transportation by water.

If a special provision is listed in the table but does notapply to the chosen mode of transport, it can be disagreed.Only investigate applicable special provisions. See 49 CFR172.102 for the identification of the special provisions.

Column 8 - Packaging AuthorizationsColumn 8 is designed as a reference and is divided intothree categories: exceptions (8A), non-bulk packaging(8B), and bulk packaging (8C). Although packagingrequirements are found in 49 CFR part 173, Column 8communicates the section number of part 173, wherespecific packaging requirements are listed.For example:Acetone (in a non-bulk package - Column 8B) referencessection 202. Refer to part 173, section 202 (49 CFR173.202) to locate specific packaging requirements foracetone.

Hazardous Materials Special Provisions

Shipping Names 2 7

Acetone T8

Methylhydrazine 1,B9,B14,B30,B72,B77,N34,T38,T43,T44

Nitric Acid, 2,B9,B32,B74,T38,T43,T45Red Fuming

Sulfuric Acid A3,A7,B3,B83,N34,T9 T27



“None”, listed in column 8A, denotes that there are noexceptions. “None” listed in either column 8B or 8C,denotes that the U.S. DOT has not authorized material to bepackaged in this manner.

49 CFR 173 also states that:“Each package must be constructed and maintained so thatthere will be no identifiable release of hazardous materialsto the environment; the effectiveness of the package will notbe substantially reduced; and there will be no mixture ofgases or vapors in the package which could, through anycredible spontaneous increases of heat or pressure, signifi-cantly reduce the effectiveness of the packaging.”

Consequently, if there is any possibility that the containercould rupture and leak, it should either be overpackedbefore shipping, or should not be shipped at all.

Column 9 - Quantity LimitationsColumns 9A and 9B specify the maximum quantity ofhazardous material that may be transported in any onepackage. Column 9A refers to transportation by passengeraircraft or rail car, while Column 9B refers to cargo aircraftonly. “Forbidden” means material may not be transportedby that particular mode. Quantity limitations are netphysical material, unless otherwise specified. All quantitiesare listed in metric units of measure.

L = liter (approximately 1 quart)kg = kilogram (approximately 2 pounds)

Hazardous Materials Packaging Authorizations 8Shipping Names (173.***)

2Exceptions Non-Bulk Bulk 8A 8B 8C

Acetone 150 202 242

Methylhydrazine None 226 244

Nitric Acid, None 227 244Red Fuming

Sulfuric Acid 154 202 242



Column 10 - Stowage RequirementsColumn 10 specifies stowage requirements aboard waterbearing vessels. For more information refer to 49 CFR172.101 [(k)].

Activity

Hazard Classes

The hazard class system is illustrated on the next page andlists hazard classes from the most dangerous to the leastdangerous. There are nine hazard classes. When a hazardclass is shown on labels, markings, placards, and shippingpapers, it is indicated by numbers 1 through 9. Somehazard classes have subclasses, which are called divisions.A division is indicated by a number to the right of thedecimal. If a hazard class and division applies to a particu-lar hazardous material, use the appropriate class number,followed by a decimal and division number (e.g., 1.6). Thenumber to the left of the decimal is the hazard class number(in this case, “1” indicates an explosive) and the number tothe right of the decimal is the division number. In this case,“.6” indicates an extremely insensitive explosive.

Hazardous Materials Quantity LimitationsShipping Names 2 9

Acetone 5L 60L

Nitric Acid, Forbidden ForbiddenRed Fuming

Methylhydrazine Forbidden Forbidden

Sulfuric Acid Forbidden 30L



In addition to hazard class and division, a packing group and hazard zone system is used to

HAZARD CLASSES

Hazard Class Hazard Class Hazard Class/ Hazard Division

Description Division Description

1 Explosives 1.1 Mass Explosion Hazard1.2 Projection Hazard

1.3 Fire Hazard1.4 No Blast Hazard1.5 Insensitive Explosive1.6 Extremely Insensitive Explosive

2 Compressed Gases 2.1 Flammable2.2 Non-Flammable and Non-Poisonous2.3 Poisonous

3 Flammable Liquid NO DIVISIONS

4 Flammable Solid 4.1 Flammable Solids4.2 Spontaneously Combustible4.3 Dangerous When Wet

5 Oxidizers 5.1 Oxidizers

5.2 Organic Peroxides

6 Poisons 6.1 Poisons

6.2 Etiologic Agents

7 Radioactive NO DIVISIONS

8 Corrosives NO DIVISIONS

9 Misc. Hazards NO DIVISIONS



further define hazardous materials. There are three packinggroups. They are:

PG I Great DangerPG II Moderate DangerPG III Minor Danger

Packing groups determine several key issues in the ship-ment of hazardous materials. For instance, packing groupshave an impact on the:

• Type of packaging• Markings• Quantity restrictions• Mode of transportation

Every hazardous material has a packing group, except Class2 (Gases) and Class 7 (Radioactive) materials.

Materials that are poison-by-inhalation (PIH) have a hazardzone. There are four hazard zones: A, B, C, and D. Thosematerials in class/division 2.3 or 6.1 may be PIH materials.



Class 1 Explosives

An explosive is any substance designed to function byexplosion (i.e. an extremely rapid release of gas and heat)or act like an explosive because of an internal chemicalreaction. Explosives in Class 1 are divided into six divi-sions. Each division has a letter designation.

Division 1.1 Division 1.1 consists of explosives that havea mass explosion hazard. A mass explosionis one that affects almost the entire loadinstantaneously. Examples of Division 1.1explosives include black powder, dynamite,and TNT.

Division 1.2 Division 1.2 consists of explosives that havea projection hazard but not a mass explosionhazard. Examples of Division 1.2 explosivesinclude aerial flares, detonating cord, andpower device cartridges.

Division 1.3 Division 1.3 consists of explosives that havea fire hazard and either a minor blast hazardor a minor projection hazard, or both, but notmass explosion hazard. Examples of Divi-sion 1.3 explosives include liquid-fueledrocket motors and propellant explosives.

Division 1.4 Division 1.4 consists of explosive devicesthat present a minor explosion hazard. Nodevice in the division may contain more than25 g (0.9 oz.) of a detonating material. Theexplosive effects are largely confined to thepackage and no projection of fragments ofappreciable size or range is expected. Anexternal fire must not cause virtually instan-taneous explosion of almost the entirecontents of the package. Examples ofDivision 1.4 explosives include line-throw-ing rockets, practice ammunition, and signalcartridges.

Division 1.5 Division 1.5 consists of very insensitiveexplosives. This division is comprised ofsubstances that have a mass explosion



hazard but are so insensitive that there isvery little probability of initiation or oftransition from burning to detonation undernormal conditions of transport. Examples ofdivision 1.5 explosives include pilled ammo-nium nitrate fertilizer-fuel oil mixtures(blasting agents).

Division 1.6 Division 1.6 consists of extremely insensi-tive articles that do not have a mass explo-sive hazard. This division is comprised ofarticles that contain only extremely insensi-tive detonating substances and that demon-strate a negligible probability of accidentalinitiation or propagation.

Class 2 Gases

The materials included in Class 2 are compressed gases.The gases are divided into three divisions. Notice that thebasic shipping description for a material in Class 2 does notinclude a packing group!

Division 2.1 Flammable gases are defined as “a materialwhich is a gas at 68°F or less and 14.7 psiand which is ignitable at 14.7 psi when in amixture of 13% or less by volume with air,or has a flammable range at 14.7 psi withair of at least 12%, regardless of the lowerflammable limit.” An example of a basicshipping description for a flammable gas:Butylene, 2.1, UN 1012.

Division 2.2 Non-flammable, non-poisonous compressedgases are described as “a material or mix-ture that has an absolute pressure of 41 psiat 68°F and does not meet the definition ofDivision 2.1 or 2.3.” An example of thebasic shipping description for a non-flam-mable, non-poisonous gas is Bromotrifluor-omethane, 2.2, UN 1009.



Division 2.3 Gases that are poisonous by inhalation areknown to be toxic to humans and, therefore,pose a hazard to health during transporta-tion. Because all Division 2.3 materials arepoisonous-by-inhalation, they will be as-signed one of four hazard zones (A,B,C,D).The hazard zone indicates the intensity ofthe hazard. In general, Zone A is the “mostpoisonous” and Zone D the “least poison-ous.” Zone definitions are based on anestablished toxicity values (LC

50) deter-

mined from animal testing. For moreinformation on gases which are poison-by-inhalation, refer to 49 CFR 173.133. Anexample of a compressed gas that is poison-ous-by-inhalation is hydrogen sulfide gas.

Class 3 Flammable andCombustible Liquids

Flammable Liquid

A flammable liquid is defined as “a liquid having a flashpoint of not more than 60.5°C (141°F).” Examples ofClass 3 materials include acetone and isopropanol. Class 3materials are divided into packing groups based on theirdegree of danger. The following chart distinguishes amongClass 3 packing groups.

Hazard Zone InhalationToxicity

A LC50

< 200 ppm

B 200 ppm < LC50

< 1000 ppm

C 1000 ppm < LC50

< 5000 ppm

D 3000 ppm < LC50

< 5000 ppm



Initial Boiling Point (°C)

Combustible Liquid (49 CFR 173.120)

A combustible liquid has a flash point greater than 141°F/less than 200°F and does not meet the definition of anyother hazard class. A flammable liquid may be reclassifiedas a combustible liquid if the flash point is greater than100°F/less than 141°F and the liquid does not meet thedefinition of any other hazard class. Hazardous materialsregulations allow the shipper latitude over shipment ofmaterials with a flashpoint between 141° and 200°F.

Class 4 Flammable Solids

Class 4 has three divisions: 4.1 (flammable solids), 4.2(spontaneously combustible), and 4.3 (dangerous whenwet). Even though the description of this hazardous charac-teristic identifies these materials as flammable solid, Divi-sion 4.2 materials do not have to be solid. For example, if aliquid is pyrophoric, it will be classed Division 4.2. Theproperty of spontaneous combustion is more importantthan the form of the material.

Division 4.1 Flammable solids include the followingmaterials:• Wetted explosives• Self-reactive materials• Readily combustible solids• Metal powders

Specific examples of Division 4.1 materials are as follows:hexamine; lead phosphate, dibasic; barium azide, wetted.

PG Flash Point (Closed-Cup) Initial Boiling Point

I < 35 C

II < 23 C > 35 C

III > 23 C < 60.5 C > 35 C



Packing groups for Division 4.1 materials are based on thematerials burning rate and zone of reaction. The followingtable shows the conditions of each packing group.

Division 4.2 Spontaneously combustible materials,including the pyrophorics and self-heatingmaterials, are included in Division 4.2.Specific examples are potassium sulfide andaluminum borohydride.

PG Burning Rate Zone of Reaction

(Metallic Powders)

I None None

II > 2.2°C mm/s and the < 5 minutes

flame passes wet zone

III < 2.2 mm/s 5 minutes <

wet zone stops flame zone of reaction

< 10 minutes

PG Pyrophoric Liquids Self-Heating PositiveTest Cube Size

I All Pyrophorics N/A

II N/A 2.5 mm

III N/A 10.0 mm



Division 4.3 Dangerous when wet materials may ignitespontaneously or give off flammable or toxicgas when in contact with water. Specificexamples are aluminum carbide,ethyldichlorosilane, and metal alloys.

Class 5 Oxidizers

Oxidizers release oxygen, which enhances the combustionof other materials. Class 5 materials are chemically activeand are often involved in industrial reactions. For example,when an oxidizer is mixed with an organic, the result couldbe an explosion. Consequently, basic chemistry mandatesisolation or segregation of Class 5 materials.

Division 5.1 An oxidizer is a material that may, byyielding oxygen, cause or enhance thecombustion of organic materials, such aswood or solvents. Examples are nitratesand aluminum dichromates. Packinggroups are determined by mean burn timesof the unknown, then compared to burntime of either an ammonium persulfatemixture or a potassium perbromate mix-ture.

Packing Group Evolution of Gases (Flammable gasevolution is measured in liters/kilograms per-time unit.)

PG I Spontaneous Ignition

> 10 l/kg Any Minute

PG II > 20 l/kg Per-Hour

PG III > 1 l/kg Per-Hour



(mbt = mean burn time)

Division 5.2 Organic peroxides are identified by hazardclass/division 5.2. Specific packagingrequirements can be found in 49 CFR173.225. Two significant hazards areassociated with a 5.2 material:

• The tendency to deflagrate• The tendency to detonate

Consequently, all class 5.2 organic perox-ides are found in Packing Group II. Spe-cial packaging requirements are necessaryfor the organic peroxides. Benzoyl perox-ide is an example of a division 5.2 mate-rial.

Activity

Packing Group Mean Burn Time

PG I mbt < mbt KBrO3

PG II mbt > mbt KBrO3

mbt < mbt KClO4

PG III mbt > mbt KClO4

mbt < mbt (NH4)

2S

2O

8



Class 6 Poisons

Poisons are materials likely to harm human health if con-tacted. Poisons can enter the body by inhalation, ingestion,or absorption. The USDOT has also incorporated theetiological (disease causing materials) agents into hazardclass 6. Packing Groups as well as hazard zones may beassigned to hazard class 6 materials. Chlorinated solvents,such as carbon tetrachloride and methylene chloride, areclassified as Class 6.1 materials.

Division 6.1 Poisons are materials (other than gases)known to be toxic during transportation orhave a toxic effect on test animals. Somedivision 6.1 poisons are poisonous byinhalation. Examples of 6.1 materialsinclude: calcium cyanide, nicotine, andmethyl isocyanate. The table below associ-ates hazard zone and Packing Group toanalytical data obtained for the poisons.Information can be found in RTECS (TheRegistry for Toxic Effects of ChemicalSubstances). The RTECS reference can beobtained through the local governmentbookstore.

Packing Group Oral Toxicity Dermal Toxicity Inhalation Toxicity (mg/kg) (mg/kg) (dust/mist) (mg/L)

I < 5 < 40 < 0.5

II > 5 < 50 > 40 < 200 < 0.5 < 0.2

III solids > 200 < 1000 > 2 < 10

> 50 < 200 liquids > 50 < 500



The packing group and hazard zone assignments for liquidsbased on inhalation of vapors must be in accordance withthe following table:

Division 6.2 Substances that contain a viable microor-ganism or microbial toxin and have thepotential to cause disease in humans oranimals are regulated as hazardous materi-als, identified in hazard class/division 6.2.This includes biologically infectious mate-rials or etiological agents. Examples ofclass 6.2 materials include: blood, bloodcontaminated equipment, and aflatoxins.

Packing Hazard Zone Vapor Concentration and ToxicityGroup

I A V > 500 LC50

and LC50

< 200 mL/M3.

I B V > 10 LC50

; LC50

< 1000 mL/m3;and the criteria for Packing Group I,Hazard Zone A are not met.

II V > LC50

; LC50

< 3000 mL/m3;and the criteria for Packing Group Iare not met.

III V > .2 LC50; LC50 < 5000 mL/m3;and the criteria for Packing Groups Iand II are not met.

.



Class 7 Radioactive Material

A radioactive material emits ionizing radiation. Materialwith an activity of 0.002 micro curies per gram or more issubject to regulation. Activity is measured at the packagesurface. Materials within hazard class 7 do not have pack-ing groups. Instead, Roman Numerals are used to commu-nicate the intensity of the radiation emitted from the pack-age. Radioactive III is assigned to packages emitting themost radiation.

Radioactive III > 50 milliroentgens per hour(mr/hr)

Radioactive II > .5 mr/hour and < 50 mr/hr

Radioactive I < .5 mr/hr

Examples of Class 7 materials include carbon 14, uranium235 and thorium compounds.

Class 8 Corrosive Material

A solid or liquid that causes irreversible harm to humanskin (necrosis) over a specified (4 hour) period is regulatedas a corrosive. A liquid causing severe corrosion(6.25 mm/g at 55 degrees C) on steel or aluminum is alsoregulated as a corrosive.

As of December 29, 1994, the US DOT now allows the useof pH to determine corrosivity. Class 8 materials arechemically described as either acidic (a low pH) or basic (ahigh pH). Corrosives are assigned to packing groups basedon necrosis time.

There are no divisions associated with hazard class 8.Examples of corrosive materials include: mercury, batteryacid, nitric acid, sulfuric acid and sodium hydroxide.



Generic shipping names must accurately describe thehazardous materials being transported. The term “Corro-sive” is no longer descriptive enough. The words organic,inorganic, acid, and/or base must be included as part of theproper shipping name. (i.e. corrosive liquid, acidic, organic,n.o.s.)

Class 9 MiscellaneousHazardous Materials

This hazard class encompasses “everything else.” A mate-rial which “presents a hazard during transport, but whichis not included in any other hazard class, may be trans-ported as a class 9 hazardous material.” Any materialregulated as a hazardous substance, hazardous waste, ormarine pollutant must be regulated during transportationand described by hazard class 9. Listed below are the mostcommon generic shipping names used to transport hazardclass 9 materials.

• Hazardous waste liquid, n.o.s., 9, NA 3082, III• Hazardous waste solid, n.o.s., 9, NA 3077, III• Environmentally Hazardous Substance, Liquid, n.o.s.,

9, UN 3082, III• Environmentally Hazardous Substance, Solid, n.o.s., 9,

UN 3077, III

Notice the UN/NA Identification numbers. The numbersare different for liquids and for solids. It is recommended

PG Necrosis Time (Minutes)

I < 3 min

II 3 min < Necrosis Time < 60 min

III 60 min < Necrosis Time < 240 min

or 1/4” corroding rates on steel or

aluminum surfaces per year



that shippers use the “Environmentally Hazardous Sub-stance” shipping name when shipping materials which donot appear on the hazardous materials table but areregulated by another federal agency (EPA or OSHA).

Other Regulated Materials

“ORM” hazard classes no longer exist. The exception isthe ORM-D hazard class. Consumer commodities will betransported as an ORM-D. Materials packaged and distrib-uted in a form intended for retail sale or for consumptionby individuals for the purpose of personal care/householduse are consumer commodities. Note that consumer com-modities are not exempt from the hazardous materialregulations. Instead, handle the consumer commodity as aspecific hazardous material. Packaging requirements,marking requirements, and labeling requirements will besubject to US DOT regulation. Molten sulfur is an exampleof an ORM-D material.

Activity



Shipping Papers

Shipping papers communicate information regarding amaterial’s hazard and must accompany every hazardousmaterials shipment transported by train, plane, vessel ortruck.

Shipping papers available at an incident scene aid youremergency response. The U.S. DOT regulates transporta-tion by several modes of transportation, including air,water, rail, and highway. Shipping papers are specific tothe mode of transportation.

The following pages contain samples of shipping papers.Each shipper, also known as a consignor, can create ship-ping papers. However, Title 49 of the Code of FederalRegulations requires specific information on shippingpapers, including:• Consignor (name, address)• Consignee (name, address)• Shippers Certification• Basic Shipping Description• Quantity Shipped

Transportation Shipping Paper Responsible Person Mode Title

Highway Bill of Lading or Uniform DriverHazardous Waste Manifest

Rail Waybill Crew

Water Dangerous Cargo Manifest Captain

Air Air Bill with Shipper’s PilotCertification for RestrictedArticles









Basic Shipping Description

The basic shipping description consists of four elements:• proper shipping name• hazard class• identification number• packing group

You can find information needed for the basic shipping de-scription in the hazardous materials table.

Shipping papers communicate information based on theproper shipping name assigned to the hazardous material.There are two types of shipping names associated withhazardous materials. These shipping names are applicablefor transportation of hazardous wastes, hazardous materials,or hazardous substances.

Technical Shipping Names are used when transporting asingle hazardous material. The word mixture or solution isadded to the technical shipping name if the single hazard-ous material has been mixed with a non-hazardous or non-regulated ingredient.

Generic Shipping Names are used when transporting amixture of two or more hazardous materials. Identify thegeneric shipping name by the letters n.o.s. “End-use”names are also classified as generic shipping names.

There are two pieces of information which may appearbefore the proper shipping name (PSN).

Required Hazardous Materials Shipping Paper Table Column Information

Proper Shipping Name 2

Hazard Class 3

Identification Number 4

Packing Group 5



First, the word “waste” will appear before the PSN (if it isnot a part of the shipping name) only if the hazardousmaterial being transported is an EPA designated hazardouswaste.

Second, the letters “RQ” may appear before the PSN. Theletters RQ will appear if the quantity transported, in asingle container, exceeds the designated reportable quantity.

Refer to Title 49 of the Code of Federal Regulations172.101 Appendix A. The table below lists examples ofbasic shipping descriptions. Each example communicatesinformation concerning a hazardous waste. When shippinga hazardous material, use the same information in the sameorder. The only difference is the omission of the wordwaste.

To be current, the shipping papers must:

• Use numerical divisions and hazard classes

• Communicate information concerning packing groupsin Roman Numerals

Classification of MaterialsContaining Multiple Hazards

Hazardous materials can contain multiple hazards. Whenmultiple hazards are present, determine the hazard prece-dence by use of the following series of tables.

Acetone, 3, UN1090, PG II

RQ Environmentally Hazardous Substance, liquid, n.o.s., 9,UN 3082, III (PCBs or Polychlorinated Biphenyls)

RQ Hazardous Waste, Solid, n.o.s., 9, NA 3077,III (D008)

Benzonitrile, 6.1, UN 2224, II

RQ Waste Formaldehyde, solutions, flammable, 3,UN2209, III



The Precedence Chart should only be used if items 1through 7 are not applicable.

Directions for use of the Precedence Hazard Table on thefollowing page:First, determine the hazard class and packing group foreach constituent material in the mixture. Utilize the tablelike a multiplication chart, plug information from oneconstituent along the top and information from the secondconstituent along the left. The point of intersection deter-mines the primary hazard. The subsidiary hazard is NOTrepresented on the chart.

Step 1 Class 7

Step 2 Class 2.3

Step 3 Class 2.1

Step 4 Class 2.2

Step 5 Class 6.1 which are PIH

Step 6 Class 4.2

Step 7 Class 4.1

Step 8 Use Precedence Chart*

Step 9 Combustible Liquids

Step 10 Class 9



Precedence Table1 There are at present no established criteria for determining Packing Groups for liquids in Division 5.1.2 Substances of Division 4.1 other than self-reactive substances.3 (3) denotes an impossible combination.



Labeling and Marking

Hazardous materials containers must be properlymarked and labeled before transport. Labels repre-sent the hazard of the material in the package.Labels are dictated by the U.S. DOT. Labels speci-fied in column 6 of the Hazardous Materials Tableare required during shipment domestically orinternationally. These labels will help respondersidentify materials involved in an incident.

Labels

A label describes the hazards of the material within acontainer. Examples of labels include the hazard label andthe inhalation hazard label (if applicable).

When the hazardous material presents multiple hazards,multiple labels must be used. The first label listed incolumn 6 is the primary hazard label; all others aresubsidiary hazard labels. Warning labels should beplaced within six inches of the product or waste label andno more than six inches from each other. Also, the primarylabel should be above and to the left of the subsidiary label.Remember the subsidiary label will not have a number inthe bottom corner indicating hazard class.

Placement of Labels

Labels should be located near the proper shipping nameand on the same surface. Labels should not be placed onthe bottom of a container and must be visible even whileriding in a vehicle. The label may not be obscured bymarkings or other attachments and labels must be indicativeof the hazard the material presents. It is illegal to placelabels on containers which present no hazard.

Marking Requirements

A marking is information that is placed onto the containerof a hazardous material before shipping. Markings do notdescribe the hazard associated with the material, instead amarking describes the package and the material inside the



package. Markings can also indicate package orientation.Preprinted forms containing marking information can beapplied to the container and/or markings can be indeliblymarked (engraved, molded, or printed) onto the container.Marking requirements are divided into five components.

Inhalation Hazard

Inhalation hazard markings are required for Division 2.3materials and Division 6.1 materials which are poisonousby inhalation. The words “Poison-Inhalation Hazard” andthe words “Hazard Zone A”, “Hazard Zone B”, “HazardZone C”, or “Hazard Zone D” will be entered on the ship-ping paper in association with the shipping description.

The words “Inhalation Hazard” will be:

• Entered on each shipping paper in association with theshipping description

Proper shipping names Include identification numbers

Technical names Only for material shipped undera generic shipping name

Special hazard warnings Package orientation markingEx: “Inhalation Hazard”

“Marine Pollutant”“RQ”

Exemptions There are occasions when the material that istransported can be placed in containers thathave an exemption. If for some reason amaterial is covered by an exemption, thenthe container should be marked with DOT-Efollowed by the exemption number that hasbeen assigned by DOT.

Consignee name The consignor is the organization where aand address shipment begins. Shipments are made to the

consignee.



• Marked on each non bulk package in association withthe proper shipping name and identification number

• Marked on two opposite sides of each bulk package.Size of markings on bulk packages must conform to172.302 (b) of this subchapter

Inhalation hazard labels should be within two inches of theproduct label and on the top of the container.

This End Up

All non bulk combination packages of hazardous materialshaving inner packaging containing liquid hazardous materi-als must be:

• Packed with closures, upward• Legibly marked with package orientation arrows (ISO

standard) on two opposite vertical sides with the arrowspointing up

Note: Although arrows for purposes other than indicatingproper package orientation may not be displayed, excep-tions do exist.

This marking is applied to containers which hold “non-specification” inner packaging of liquid hazardous materi-als. An outer package which contains an inner package isknown as a combination package. The inner packages maybe containers made of glass, plastic, or even metal. Theinner packages do not have to be U.S.DOT approvedcontainers. Combination packages are not only markedwith orientation arrows but must also have the inner pack-age closures oriented upward. Orientation arrows require-ments do not apply if the inner package:

• Is a cylinder• Contains one liter or less of a flammable liquid and is

being transported by rail, highway, or vessel• Contains liquids which are a part of a leak-tight manu-

factured article



Requirements when using “This End Up” labels:

• All inner packaging containing liquids must be arrangedso that their openings correspond to the label arrowdirection.

• The outside container must be marked with packageorientation labels on two opposite sides.

• These package orientation labels must meet certainstandards, meaning that they cannot be drawn on thecontainer.

Activity

U.S. DOT Package Marking

As of October 1, 1994, only UN approved packages will beproduced. Package markings must be indelibly entered ontothe package and indicate UN approval. UN package mark-ings are required for packages containing hazardous materi-als. The United Nations specification containers use astandard code to designate container type. The code con-sists of the following nine parts:

• UN Symbol• Package code• Packing group code• Gross mass• Solid or liquid packaging• Year of manufacture• Country where package was tested• Registered code of manufacturer• Reconditioning certification

Part 1 (UN Symbol)

The UN symbol looks like this:

UN



Part 2 (Package Code)

The packaging code consists of numbers and letters. Thefirst number communicates information concerning the typeof package.

1) Drum2) Wooden Barrel3) Jerrican4) Box5) Bag6) Composite Packaging7) Pressure receptacles

The letter or letters indicate package constructionmaterial(s).

A) SteelB) AluminumC) Natural WoodD) PlywoodG) FiberboardH) PlasticL) TextileM) Paper, multiwallN) Metal (other than steel or aluminumP) Glass, porcelain or stoneware

The last number identifies the package closure or lid

1. Closed Top2. Open Top

Part 3

The packing group is also designated within the packagemarking. Use the following key to signify packing groupsacceptable for transport within the package.

• X* = for Packing Group I, II, and III• Y = for Packing Group II and III• Z = for Packing Group III

1 A H 2



Note: “X” containers must meet the most stringent stan-dards and severe package testing requirements, thus anypacking group can be shipped in “X” containers.

Testing requirements include, but are not limited to:

• Drop Test• Vibration Test• Leakproof Test and• Stacking Test.

The severity of the test requirement is indicated by thematerial the package can contain. If the package is de-signed to contain a Packing Group I material, then the moststringent performance requirements must be met. Forexample, the performance standards for the drop test of an“X” package require that the container be dropped from aheight of approximately six feet without leaking or denting.A “Y” package is dropped from a height of approximatelyfour feet, and a “Z” package is dropped from a height ofabout two feet without denting or leaking. The most dan-gerous materials will be shipped in the strongest package.

Part 4

Packages intended to house solid materials will be tested inaccordance with a pre-determined statistical quality controlplan. Packages intended to house a solid will have an “S”in box four. The number listed in conjunction with the “S”indicates the gross mass (in kilograms) to be housed by thepackage. In the following example, the container is in-tended for only a solid and the maximum gross weightassociated with the container is 165 kilograms.

If a package is designated to contain liquids, two numberswill appear in box four. The first number communicates themaximum specific gravity the container can hold. Thesecond number communicates (in kilopascal) the pressurethe container was tested under.

S 165

1.4 160



Every container intended to house a liquid must be perfor-mance tested. In the above example, the container isintended to house a liquid, in fact the maximum specificgravity associated with the liquid is 1.4 gm/cm3. In addi-tion, the container was tested in the leakproof test under160 kpscal of pressure.

Part 5 through 7

Box 5 - The year of manufacture is listed in box 5.Appearing in box 5 will be the last twodigits associated with the calendar year inwhich the container was made.

Box 6 - The symbol for the country where thecontainer was manufactured will be listed inbox 6. American manufactured UN contain-ers will have a USA in box 6.

Box 7 - The last standard part of the UN markingwill be the name of the manufacturer’s nameor registered symbol (U.S. DOT registered).

Part 8

A thickness will be included in the marking only if thecontainer may be re-used. If a thickness (in mm) does notappear as the last part of the marking then the container is asingle use container. The container must never be retestedfor reuse. If the thickness exceeds 8 mm, then the containercan only be reused after retesting. Send the DOT emptycontainer to an approved re-conditioner, who will restampthe container once the performance retest has been com-pleted.

Example of a UN Code

Package intended for solid material

U N

1AH2 Y 145 S 92 USA VL 6mm 824



Package intended for a liquid material

Re-tested package label

DOT Load Segregation

DOT outlines specific segregation and separation require-ments for hazardous materials shipments. The segregationtable on the next page will help you determine the relativecompatibility of materials during a hazardous materialsincident. This does not show the hazards of chemicalsmixing or the resultant product of the mix. Extreme cau-tion should be exercised when chemicals mix.

Activity

U 1AH2 Y 1.4 92 USA VL 6mm

10-93 USA VL824 RL



Instructions for the Segregation Table of Hazardous Materials

1. No restrictions are applicable if there is a blank space.2. “X” indicates that materials cannot be loaded, transported, or stored together in the same transport vehicle.3. The letter “O” in the Table indicates that these materials may not be loaded, transported, or stored together in

the same transport vehicle or storage facility during the course of transportation unless separated in a mannerthat, in the event of leakage from packages under conditions normally incident to transportation, commingling ofhazardous materials would not occur. Not-withstanding the methods of separation employed, Class 8 (corrosive)liquids may not be loaded above or adjacent to Class 4 (flammable) or Class 5 ( oxidizing) materials; except thatshippers may load truckload shipments of such materials together when it is known that the mixture of contentswould not cause a fire or a dangerous evolution of heat or gas.

4. “A” indicates that ammonium nitrate fertilizer may be loaded or stored with Division 1.1 (Class A explosive) orDivision 1.5 (blasting agent) materials. Refer to the Explosive table in order to determine compatibility groups.

5. When a package has a subsidiary hazard label, segregation appropriate to the subsidiary hazard must be appliedwhen that segregation is more restrictive than that required by the primary hazard.

6. Cyanides or cyanide mixtures cannot be loaded or stored with acids.7. Division 6.1, PG I, Zone A cannot be loaded, transported, or stored with Class 3, Class 4, and Class 5.



Occupational Safetyand HealthAdministration (OSHA)

Questions

1. Is your state covered by OSHA or subject to EPAstandards?

2. How do regulations from these two agencies differ?

The second phase of a hazardous materials life cycle isreceipt of the material into a facility and its subsequent use.After a DOT hazardous material is received into a facility, itis no longer regulated by DOT because it is no longer beingtransported. Inside the facility, the safe use and marking orcommunication of the hazards of the product is now regu-lated by the Occupational Safety and Health Administration(OSHA). Title 29 of the CFR deals with Worker Protection.This two-set volume of regulations covers a broad range ofworkers. We will specifically address those workers whoare considered to work in general industry.

Regulated Sites

There are many different types of sites that use or storehazardous materials. Generators have disposal storage areaswhere waste is picked up. These areas may be inside oroutside. Superfund sites are usually larger old dump siteswhere containers are being extracted from the ground.Clean-up sites can be small spills from tank cars or nearbyroadways or can be areas contaminated from industrialequipment use. Waste from generators may pass through atransfer and storage facility where containers are movedfrom one transportation vehicle to another. Hazardousmaterials are also used during production at many industrialsites. Training is required for involvement in emergencyresponse to incidents at these industrial sites.



Minimizing Work Place Hazards

To work in a safe and healthy environment, workers mustparticipate actively in a comprehensive safety program.One key element of any safety program is the goal tominimize hazards in the work place. In order to success-fully minimize hazards, you must first determine whichhazards are present. To minimize risks, employers typicallyinstitute a health and safety program that is cyclic andincludes three phases: recognition, evaluation, and control.The first step is recognizing or identifying real and potentialhazards and risks. Second, employers evaluate the effectthese hazards have on the work force and compare theseeffects against industry standards. Finally, employers arerequired to outline methods of hazard control. No employeris permitted to expose workers to a chemical hazard inexcess of OSHA designated levels.

Compliance

The Occupational Safety and Health Administration, createdwithin the Department of Labor, outlines requirementsincluding training for individuals working with hazardouschemicals. These health and safety requirements are foundin 29 CFR 1910. OSHA also assists in creation of personalprotective equipment standards and helps in regulation ofspecific processes, including lockout/tagout, confined spaceentry, and electrical safety. In its procedures, OSHA guar-antees employers and employees the right to be fully in-formed, to participate actively, and to appeal actions.

OSHA’s scope includes all employers and their employeesin the 50 states, the District of Columbia, Puerto Rico, andall other territories under Federal Government jurisdiction.Those persons not covered under OSHA include:

• Self-employed persons• Farms at which family members are employed• Work places already protected by other federal

programs under other federal statutes

Some states are covered by OSHA regulations; others arenot. States not covered by OSHA are subject to EPA healthand safety standards.



Standards Promulgated by OSHA

OSHA is responsible for promulgating legally enforceablestandards. OSHA standards fall into four categories:

• General Industry• Maritime• Construction• Agriculture

Occupational Illness and Injury

Facilities with 11 or more employees must maintain recordsof occupational injuries and illnesses as they occur. Anoccupational injury is an injury such as a cut, fracture,sprain or amputation which results from a work-relatedaccident or from exposure involving a single incident in thework place. An occupational illness is any abnormalcondition or disorder other than one resulting from aninjury, caused by exposure to environmental factors associ-ated with employment. Included are acute and chronicillness or diseases which may be caused by inhalation,absorption, ingestion, or direct contact with toxic sub-stances or harmful agents.

Safety and Health Programs

All employees are required to comply with a health andsafety program. Most facilities choose to extend thisprogram to contractors, subcontractors, visitors, regulatoryagency personnel, and site owners or their representatives.The rights and responsibilities of employees and the em-ployer are described by OSHA.

OSHA has several standards that apply to the health andsafety of workers. Some of the standards that apply toindustry are:29 CFR 1910.1200 Hazard Communication29 CFR 1910.120 Hazwoper29 CFR 1910.146 Confined Space29 CFR 1910.1030 Bloodborne Pathogens29 CFR 1910.147 The Control of Hazardous Energy29 CFR 1910.133 Eye and Face Protection29 CFR 1910.134 Respiratory Protection29 CFR 1910.135 Occupational Head Protection29 CFR 1910.136 Occupational Foot Protection



29 CFR 1910.138 Occupational Hand Protection29 CFR 1910.95 Occupational Noise Exposure

Following is an overview of these standards.

Hazard CommunicationStandard (29 CFR 1910.1200)

OSHA has written a standard that requires employers toidentify the hazards present in the work place. The hazardcommunication standard, written in 1987, outlines methodsfor identifying and communicating the presence of hazards.Also known as the employee Right-to-Know law, thehazard communication standard applies to all chemicalsthat pose hazards to the workers. This standard categorizeschemicals based on their threat to human health. Hazardsat hazardous waste operations and emergency responsesites can be classed into two categories: safety hazards andchemical hazards.

Chemical hazards pose either a health hazard or a physicalhazard to the worker. While there are two broad categoriesof hazards, the hazard communication standard only ad-dresses the chemical hazards present in the work place.

Safety hazards consist of hazards such as noise or thermalextremes. Safety hazards result from conditions in thework place that might harm workers. Safety hazardsinclude:

• High noise levels• Oxygen deficient or enriched conditions• Shock hazards• Static discharges• Mechanical hazards• Thermal extremes• Poor ergonomics• Hazards from welding/cutting/brazing operations• Excavation hazards• Hazards from ionizing radiation

Safety hazards can be identified in the work place usinggood hazard communication labels. Various types ofhazards are shown on the following pages.



Types of Hazards

Hazards

Safety Chemical

Physical Health

v

v v

v

v v



Chemical Hazards

Health

Carcinogens Sensitizers Irritants Reproductive Corrosives Poisons

v

v v v v v v



Chemical Hazards

Physical

Explosives Flammables Reactives Oxidizers

Water AirPyrophoric Combustibles



HAZWOPER(29 CFR 1910.120)

OSHA’s 29 CFR 1910.120 deals with hazardous wasteoperations and emergency response. The standard targetsthree separate groups of workers including:

• Employees who work at RCRA facilities

• Employees who respond to emergencies

• Employees who work at clean-up sites dealing withhazardous substances

29 CFR 1910.120 is divided into seventeen paragraphs, Athrough q, and includes requirements such as medicalmonitoring, health and safety plans, and site characteriza-tion. Employees who work at RCRA facilities are coveredby paragraph P. Employees who work at clean-up sites arecovered by paragraphs B through O. Fire fighters whohandle emergency response are covered by paragraph Q.A breakdown of paragraphs B through P is in Appendix Bof this module. Paragraph q is described here.

Paragraph Q — Emergency Response

This paragraph covers employees who are responding to anemergency response regardless of the location. Elements ofparagraph Q include:

A. Development of an Emergency Response Plan with thefollowing elements:• Pre-emergency planning with outside parties• Personnel roles, lines of authority and communica-

tion• Emergency recognition and prevention• Safe distances and places of refuge• Site security and control• Evacuation routes and procedures• Decontamination procedures• Emergency medical treatment and first aid• Emergency alerting and response procedures• Critique of response and follow-up• PPE and emergency equipment



B. Procedures for handling emergency responseC. Skilled support personnelD. Specialist employeesE. Training. Five levels of training are outlined. These

five levels follow a hierarchy in terms of training andresponsibility for responding to an emergency. The fivelevels (in ascending order of responsibility) are:1. First Responder Awareness Level: Use senses and

job knowledge to be alert to an emergency andinitiate the ER team.

2. First Responder Operations Level: Recognize anemergency and take a defensive posture by isolatingthe area and containing the release.

3. Hazardous Materials Technician: Recognize thehazards of the release and take an offensive postureby stopping the release.

4. Hazardous Materials Specialist: Support the techni-cian with a more specialized knowledge of thehazards present.

5. On-site Incident Commander: The most seniorofficial at the scene. Responsible for making thedecisions and assigning duties.

F. TrainersG. Refresher trainingH. Medical surveillance and consultationI. Chemical protective clothingJ. Post-emergency response operations. Post emergency

response operations include possible removal of hazard-ous substances, health hazards and contaminated mate-rials.

This section was designed to introduce the various OSHAstandards that are in place today to protect the worker fromparticular safety, physical and health hazards. To find outspecific information, refer to the Code of Federal Regula-tions and your local and state regulations.



Other OSHA Standards

1910.146The Confined Space Standard identifies requirements forconfined space entry as well as practices and procedures toprotect employees from the hazards of permit-requiredconfined spaces.

1910.1030The Bloodborne Pathogen Standard covers occupationalexposure to blood or other potentially infectious materials.This standard focuses on communicable disease such asHIV and Hepatitis B.

1910.147The Control of Hazardous Energy, more commonly knownas Lockout/Tagout (LO/TO) Standard establishes minimumperformance requirements for control of energization (startup) of machines or equipment, or the release of storedenergy that could cause injury. This standard requiresemployers to publish a written LO/TO program. Facilitiesare required to institute policies and procedures whichprotect workers from mechanical hazards during routinemaintenance.

1910.133In 1910.133, OSHA identifies acceptable eye and faceprotection. Eye and face protection are required when areasonable probability of injury exists.

1910.134The primary objective of the Respiratory Protection Stan-dard is to control occupational disease caused by breathingcontaminated air. Breathing air is contaminated whenharmful dusts, fogs, fumes, mists, gases, sprays, or vaporsexist in the work place.

1910.135The Occupational Head Protection Standard requiresworkers to wear protective helmets when working in areaswhere the potential for head injury exists due to fallingobjects.



1910.136The Protective Footwear Standard protects employeesworking in areas where harmful foot exposure exists.Protective footwear must be issued when hazards fromfalling and/or rolling objects, objects piercing the sole, oreven electrical hazards are present in the work place.

1910.138Protective hand protection is mandated when employees’hands are exposed to one or more of the following condi-tions: skin absorption of harmful substances, severe cuts orlacerations, severe abrasions, punctures, chemical burns,thermal burns, and/or temperature extremes.

1910.95The Occupational Noise Protection Standard identifies thetype of protection necessary against a variety of noiseexposures. In addition, the standard requires facilities toestablish a hearing conservation program and communicatethe effects of noise exposure.

Most of these standards are referenced in 29 CFR 1910.120.In order to adequately protect the emergency responseworker or the site worker, facilities must have an extensiveunderstanding of the standards covered above. Since 29CFR 1910.120 covers these workers, we will take an in-depth look at this particular standard.





EnvironmentalProtection AgencyThe third phase of a product’s life cycle is the waste cycle.After a material has been used in a facility, it may bereprocessed and redistributed, or disposed of. Either way,a new set of regulations, enforced by the EnvironmentalProtection Agency (EPA), take effect.

U.S. EPA regulates the federal system of hazardous wastemanagement. It establishes and enforces environmentalregulations, including rules for the management of solidand hazardous wastes. In 1972, the Environmental Protec-tion Agency was formally incorporated as a part of theDepartment of Labor. Unfortunately the EPA had noenforcement power. In 1976, Congress voted yes on alandmark decision and the Resource Conservation andRecovery Act (RCRA) was voted into law. EPA enforcesRCRA. Over the next decade, Congress repeatedly stressedenvironmental issues in a series of laws assigning environ-mental responsibility to corporate America. Since 1976,the number of environmental regulations has greatly in-creased.

Environmental laws enacted by Congress include:

• Resource Conservation and Recovery Act (RCRA)

• Comprehensive Environmental Responsibility Compen-sation and Liability Act (CERCLA)

• Superfund Amendment and Reauthorization Act(SARA)

• Toxic Substance Control Act (TSCA)

• Clean Air Act (CAA)

This section takes a closer look at those environmentalregulations with the greatest impact on health and safetyconcerns.



The Resource Conservationand Recovery Act (RCRA)

The Resource Conservation and Recovery Act has beenincorporated into the 40 CFR, specifically part 260 through270. RCRA is regulated by the Environmental ProtectionAgency. The Resource Conservation and Recovery Act,written in 1976, was the first comprehensive federal effortto deal with solid and hazardous waste. Subtitle C of theAct was to form and enforce regulations concerning track-ing and managing hazardous wastes from the point ofgeneration to the ultimate disposal—“cradle to grave”management.

RCRA states that persons managing solid wastes arecharged with the responsibility of identifying those wasteswhich meet one or more of the characteristics of hazardouswastes. Such persons are responsible also for providingnotification to EPA of any waste disposal activity involvinghazardous wastes. Persons who have solid wastes that meetthe definition of hazardous wastes are known as genera-tors. Generators have the responsibility to manage hazard-ous wastes according to generator standards. These stan-dards include preparing manifests to track the shipment ofhazardous waste from the generation point to the ultimatetreatment or disposal site. Generators must also use thosetransporters and treatment, storage, or disposal facilities(TSDF) that are appropriately licensed by the federal andstate governments. Finally, RCRA gave the EPA the powerto enforce the regulations written and adopted in title 40 ofthe Code of Federal Regulations.

The following list outlines the regulations listed in the 40CFR that are applicable to RCRA. It is this portion of theregulation where definitions and generator requirements arefound.



Subpart A General

Section 261.1 Purpose and scopeSection 261.2 Definition of solid wasteSection 261.3 Definition of hazardous wasteSection 261.4 ExclusionsSection 261.5 Special requirements for hazardous

waste generated by conditionally exemptsmall quantity generators

Section 261.6 Requirements for recyclable materialsSection 261.7 Residues of hazardous waste in empty

containersSection 261.8 PCB wastes regulated under Toxic

Substance Control Act

Subpart B Criteria for Identifying the Characteristics ofHazardous Waste and for Listing HazardousWastes

Section 261.10 Criteria for identifying the characteristicsof hazardous waste

Section 261.11 Criteria for listing hazardous waste

Subpart C Characteristics of Hazardous Waste

Section 261.20 GeneralSection 261.21 Characteristic of ignitabilitySection 261.22 Characteristic of corrosivitySection 261.23 Characteristic of reactivitySection 261.24 Toxicity characteristic

Subpart D Lists of Hazardous Wastes

Section 261.30 GeneralSection 261.31 Hazardous wastes from non-specific

sourcesSection 261.33 Discarded commercial chemical

products, off-specification species,container residues, and spill residuesthereof

Section 261.35 Deletion of certain hazardous wastecodes following equipment cleaning andreplacement



Definitions

One of the basic purposes for RCRA, as it was written in1976, was to establish a framework for environmental lawand regulation. RCRA began by defining waste. Defini-tions then snowballed and as the environmental laws appeartoday, the most complex issue has been in keeping thedefinitions straight. The following definitions are encoun-tered throughout the 40 CFR 261.

Solid Waste

This is a material that has been discarded by a generator,regardless of intent. The material may be intended forrecycling or reclamation and must be classified and conse-quently regulated as a waste. A material can be declared tobe a solid waste regardless of physical state (a solid, liquid,or gas).

Lab Sample

Lab samples are not considered waste, but must be labeledin accordance with DOT regulations.

Characteristics of Hazardous Waste

A waste is declared to be a hazardous waste if it meets thedefinition of a solid waste and the definition of a character-istic waste. A characteristic waste exhibits one of fourhazardous characteristics:

• Ignitability• Corrosivity• Reactivity• Toxicity

Each of the four hazardous characteristics are measurable.Each characteristic has a specific lab-based analysis associ-ated with it. For example, a waste is ignitable if the flashpoint is less than or equal to 1400F. A flash point less than1400F indicates the waste is hazardous and should carry aD001 waste code.



Characteristics of Ignitable Waste (D001)

All solid waste that exhibits the characteristic of ignitabilitycarries the EPA designated hazardous waste code of D001.EPA regulation 40 CFR 261.21 describes four types ofignitable hazardous wastes:

• Liquids having a flash point below 140oF (These wastestreams must be non-aqueous solutions containing lessthan twenty-four percent by volume of alcohol.)

• Non-liquids (solids, rather than gases) that may causefire through friction, absorption of moisture, or sponta-neous chemical changes

• Certain ignitable compressed gases

• Oxidizers, as defined in 49 CFR 173.151 (An oxidizeris a substance, such as a chlorate, permanganate, inor-ganic peroxide, or nitrate, that readily yields oxygen toenergize the combustion of organic matter.)

Examples of D001 hazardous wastes include: acetone, hy-drogen gas; potassium sulfide; and sodium nitrate.

Characteristics of Corrosive Waste (D002)

The EPA definition of a corrosive waste (40 CFR 261.22)uses two terms - aqueous solution and liquid. Aqueoussolution is not formally defined in the regulations but, asnoted by the EPA, aqueous refers to any solution in whichthe primary component is water. Therefore, water mustcompose at least fifty percent by weight of an aqueoussolution. A corrosive waste, then, is:

• An aqueous solution with a pH less than or equal to 2 orgreater than or equal to 12.5

• A liquid that corrodes steel faster than .250 inch peryear.

Corrosive hazardous wastes, identified by EPA Code D002,include: sulfuric acid, sodium hydroxide solution, hydro-chloric acid, and ammonium hydroxide.



Characteristics of Reactive Waste (D003)

40 CFR 261.23 defines a reactive hazardous waste streamas follows:

• Normally unstable and readily undergoes violentchanges without detonating

• Can react violently with other waste(s)• Forms potentially explosive mixtures with water• Generate toxic gases, vapors, or fumes when mixed

with water that are a danger to human health or theenvironment

• Cyanide or sulfide-bearing wastes which can generatetoxic gases, vapors, or fumes when exposed to pHconditions between 2 and 12.5

Examples of reactive hazardous wastes (D003) include:potassium cyanide; lithium aluminum hydride; andtrimethylchlorosilane.

Characteristic of Toxic Waste (D004-D043)

EPA waste codes D004 through D043 have been designatedto specific organic and inorganic chemicals that are toxic.The definition can be found in 40 CFR 261.24. The exist-ence of pesticides, metals, and miscellaneous organicchemicals exceeding specified concentrations provideevidence of the characteristic toxicity. Toxicity is evaluatedusing the Toxicity Characteristic Leaching Procedure(TCLP). A solid waste that exhibits the characteristic oftoxicity has the EPA hazardous waste number specified inTable I which corresponds to the toxic contaminant causingit to be hazardous.



Regulatory LevelWaste Code Contaminant

D025 p-Cresol 200.0

D026 Cresol 200.0

D016 2,4-D 10.0

D027 1,4-Dichlorobenzene 7.5

D028 1,2-Dichloroethane 0.5

D029 1-1-Dichloroethane 0.7

D030 2,4-Dinitrotoluene 0.13

D012 Endrin 0.02

Heptachlor (and its epoxide) 0.008D031

D032 Hexachlorobenzene 0.13

D033 Hexachloroethane 0.5

D034

Lead

3.0

D008

Lindane

Hexachlorobutadiene

5.0

0.4D013

D009 Mercury 0.2

D014 Methoxychlor 10.0

D035 Methyl Ethyl Ketone 200.0

D036 Nitrobenzene 2.0

D037 Pentachlorophenol 100.0

D038 Pyridine 5.0

D010 Selenium 1.0

D011 Silver 5.0



Maximum Concentration of Contaminants forthe Toxicity Characteristic 40 CFR 261.24

Waste Codes Contaminant Regulatory Level (mg/L)

D039 Tetrachloroethylene 0.7

D015Toxaphene 0.5

0.7

400.0

2.0

1.0

0.2

D040

D041

D042

D017

D043

Trichloroethylene

2,4,5-Trichlorophenol

2,4,6-Trichlorophenol

2,4,5-TP (SIlvex)

Vinyl Chloride

Waste Code ContaminantRegulatory Level

(mg/L)

D004 Arsenic 5.0

D005 Barium 100.0

D018 Benzene 0.5

D006 Cadmium 1.0

D019 Carbon Tetrachloride 0.5

D020 Chlordane 0.03

D021 Chlorobenzene 100.0

D022 Chloroform 6.0

D007 Chromium 5.0

D023 o-Cresol 200.0

D024 m-Cresol 200.0



D004 - D011 Heavy MetalsD012 - D017 PesticidesD018 - D043 Organics

Identifying Waste

Being able to identify a waste can help you identify thedegree of danger involved. Use the following process toidentify waste.

1. Is the material a solid waste (40 CFR 261.2)?

If no, check state regulations.If yes, refer to either of these EPA regulations:• Refer to the definition of a “hazardous waste” in 40

CFR 261.3.• Refer to the waste identification process in 40 CFR

262.11(b).

2. Then determine if the waste is “listed”. Listed wastesare divided into 2 categories:

• Process Waste• Product Waste

3. If the waste is from a process, you have two choices:

• The waste is described as F-List (40 CFR 261.31)• The process is described as K-List (40 CFR 261.32)

4. If the waste is a product, refer to 40 CFR 261.33 - SoleActive Ingredient to determine if the product is:

• Acutely hazardous waste - P-List(40CFR261.33(e))

• Toxic waste - U-List (40 CFR 261.33(f))

Acutely hazardous waste is extremely dangerous in smallamounts. These wastes are regulated the same way as largeamounts of other hazardous wastes. If a company producesas little as 1 kilogram (2.2 lbs) of acutely hazardous wastesin a calendar month, or stores more than that amount forany period of time, it is subject to all of the regulations thatapply to generators of more than 1,000 kilograms percalendar month.



If the waste is not listed or land disposal restricted (40 CFR262.11(c)), then it must be determined if the waste presentsone of the four characteristics discussed earlier.

Superfund Amendments andReauthorization Act(SARA TITLE III)

SARA became law on October 17, 1986. SARA, alsoknown as the Emergency Planning and Community Right-to-Know Act (EPCRA) was written to provide state andlocal governments and the public with information concern-ing potential chemical hazards present in the community.SARA establishes requirements for industry regardingemergency planning and “Community Right-to-Know”reporting on hazardous and toxic chemicals. This lawbuilds on the EPA’s Chemical Emergency PreparednessProgram (CEPP). SARA Title III is intended to helpcommunities access information and thus better deal withthe presence of hazardous chemicals and releases of thosechemicals into the environment. Through SARA, statesand communities must work together with facilities toimprove chemical safety and protect public health. SARAhas four major provisions or sections: emergency planning;emergency release notification; Community Right-to-Knowreporting requirements; and toxic chemical release inven-tory.

Section 301-303: Emergency Planning

SARA requires the governor of each state to designate aState Emergency Response Commission (SERC). SERCsinclude public agencies involved in the environment,natural resources, emergency services, public health,occupational safety, and transportation. SERCs must alsohave designated local emergency planning districts andappointed Local Emergency Planning Committees. LEPCsinclude elected state and local officials, police, fire, civildefense, public health officials, environmental, hospital,and transportation officials as well as facility representa-tives. Finally, section 301-303 requires the development ofEmergency Response Plans by the LEPC.



Section 304: Emergency ReleaseNotification

Facilities must notify the LEPC (and consequently theSERC) of any possible environmental release of specificchemicals. The specific chemicals referred to in SARATitle III are found on the following lists: Extremely Haz-ardous Substance List (40 CFR 355); Reportable QuantityList (CERCLA Section 103(a)). Emergency notificationmust include:

• Chemical name• Identification of the chemical by list• Estimation of quantity released• Time and duration of release• Mode of release - air, water, soil• Known health risks associated with the emergency• Applicable precautions• Name and phone number of a contact person

Remember all emergency notifications require a writtenfollow-up as soon as possible.

Section 311-312: Reporting Requirements

According to SARA, facilities must provide either MSDSs(Material Safety Data Sheets) or a list of MSDS chemicalsto the SERC, LEPC, and local fire department. If facilitieschoose to supply only a list, the list must include veryspecific information regarding the health, fire, reactivityhazards, physical data, etc. for every chemical on the list.It is much simpler to provide copies of the MSDSs. Fur-thermore, facilities must complete an emergency and haz-ardous chemical inventory. This inventory is to be submit-ted to the LEPC, SERC, and local fire department. Chemi-cals included in this inventory are materials that werepresent at or above specific threshold quantities. Thespecific threshold quantities are 500 pounds for extremelyhazardous substances and 10,000 pounds for all otherhazardous chemicals. It is the hazardous chemical inven-tory that initiated the Tier I and Tier II approach.



Section 313

The EPA has established an inventory of routine toxicchemicals which require emissions reporting. These report-ing requirements are known as Form R. Facilities subject toSection 313 are required to submit a Toxic Chemical Re-lease Inventory Form for specified chemicals. Form Rnotifies public and governmental agencies about routinereleases (releases that occur as a result of daily productionuse). Form R applies to facilities of ten or more employeeswith Standard Industrial Classification (SIC) codes 20through 39, and that manufacture, process or otherwise usea toxic chemical in excess of specified threshold quantities.Form R is completed on an annual basis and is submitted byJuly 1.



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ComprehensiveEnvironmental ResponseCompensation and LiabilityAct (CERCLA)

The Comprehensive Environmental Response Compensa-tion and Liability Act, known as CERCLA, was passed inDecember 1980 and amended in 1986. This Act providesfederal authority to respond to environmental hazards posedby abandoned disposal sites, and provides the resources toclean up those sites. This Act established the reportingrequirements for the release of hazardous substances andset up a taxing system to fund site clean-ups.

In addition, CERCLA introduced the term “hazardoussubstance.” A hazardous substance is a reportable quantityof specific materials. In fact, the reportable quantity (RQ)table was first introduced by CERCLA. CERCLA deemedspecific quantities of certain materials dangerous to publichealth and the environment. Quantities are listed in the RQtable on the far right. Should an amount in excess of theRQ be released into the environment, the responsiblefacility has less than 24 hours to notify federal authorities.The DOT has adopted RQs. Consequently, if an amount inexcess of the reportable quantity is found in any singlecontainer, then an RQ must appear on the container labeland on the corresponding shipping paper. During transpor-tation, any RQ container involved in a spill or a leak situa-tion must follow special federal and local reporting require-ments. Identify reportable quantities (and consequently,hazardous substances) by the presence of RQ on the labelor shipping paper.

Toxic Substance Control Act(TSCA)

The office of Toxic Substances Control regulates specificsubstances that are hazardous by some measure, but are notnecessarily regulated by other agencies. This regulationcovers asbestos, PCB-containing materials, and thepremanufacture notice by industry for new materials.



Clean Air Act (CAA)

The primary purpose of the Clean Air Act is to prevent orminimize pollution. Congress passed this regulation toencourage and promote pollution prevention. This regula-tion is quite lengthy and details information requirementsfor commercial industries. The Act includes research,investigation, and training for pollution prevention, feder-ally assisted cost recovery for industry, air quality criteria,and state implementation of the regulation.

One of the most important pieces of this legislation forresponders is found in section 112 of the CAA. This sec-tion deals with Hazardous Air Pollutants. Specifically,CAA 112( r) deals with the prevention of accidental re-leases. The CAA addresses the accidental release of achemical that may reasonably be anticipated to cause death,injury, or serious adverse effects to human health or theenvironment. The basis for the list of chemicals comesfrom the Emergency Planning and Community Right toKnow Act of 1986 (EPCRA). This law contains a list ofExtremely Hazardous Substances (EHS or List of Lists).The list dictates a Threshold Quantity (TQ) of a substance.Facilities which store a TQ or Threshold Planning Quantity(TPQ) must report that information to the Federal govern-ment. A recently passed amendment to this law now re-quires facilities to plan a worst case scenario in case of anaccidental release of a hazardous substance.

Transportation ofHazardous Waste

The Department of Transportation regulates movement ofhazardous materials in commerce, by any mode of transpor-tation. DOT also regulates all hazardous wastes in thehazardous material regulations (HMR). Wastes are incorpo-rated by reference into the HMR from the EPA regulations.The DOT regulates both materials and waste during move-ment. The DOT classification system is specifically relativeto transportation. Remember EPA, OSHA, and DOT allhave very specific and different classification rules.



As stated earlier, a hazardous material is somethingwhich has been determined by the DOT to be “...capable ofposing an unreasonable risk to health, safety, and propertywhen transported.” Materials designated as “hazardous” bythe DOT are listed in the Hazardous Materials Table, whichcan be found in 49 CFR 172.101. Materials are listed inalphabetical order in accordancewith their proper shippingnames. The DOT has included all hazardous waste bydefinition as a hazardous material. Consequently, anythingregulated by the EPA as a hazardous waste must be shippedaccording to the DOT hazardous material regulations.

NOTE: In December 1994, approximately 33% ofthe Hazardous Material Table (49 CFR172.101) was changed under DocketHM215A [Vol. 59, No. 249, Thursday,December 29, 1994].

The RCRA regulations require a “special” shipping paperfor hazardous waste. This document may change state tostate, but the general information remains the same. Themanifest serves two purposes. First, it tracks where thewaste came from, where it is going, and who moved it.Second, it identifies the materials for emergency responders.

Activity



Hazard IdentificationOSHA defines a “hazardous chemical” as any chemical thatposes a health hazard or a physical hazard to workersduring use. Furthermore, OSHA defines the tems healthhazard and physical hazard in the Hazard Communica-tion Standard.

“Health Hazard means a chemical for which there is statisticallysignificant evidence based on at least one study conducted inaccordance with established scientific principles that acute orchronic health effects may occur in exposed employees. Theterm ‘health hazard’ includes chemicals which are carcinogens,toxic or highly toxic agents, reproductive toxins, irritants, corro-sives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agentswhich act on the hematopoietic system, and agents which dam-age the lungs, skin, eyes or mucous membranes.”

“Physical Hazard means a chemical for which there is scientifi-cally valid evidence that it is a combustible liquid, a compressedgas, explosive, flammable, an organic peroxide, an oxidizer, py-rophoric, unstable (reactive) or water reactive.”

Hazard Communication protects worker safety by ensuringthat chemical manufacturers convey to their customers andemployers convey to their employees the hazards associatedwith using, working around and exposure to hazardouschemicals in the work place. This is achieved through awritten program, labeling, Material Safety Data Sheets, andemployer training. Put more simply, hazards are identifiedby the use of:

• OSHA, EPA, and DOT markings, labels, andplacards

• Material Safety Data Sheets• Signs• Training

One means of identifying potential health and physicalhazards is through the labeling required by OSHA underthe Hazard Communication (“Right-to-Know”) standard.Both the label and the MSDS include information on thehazards of the chemical as well as first aid information.Note that OSHA does not require an MSDS for an EPA-regulated hazardous waste.



Hazard Warnings

Labels

The manufacturer, importer, or distributor is responsible forensuring that every container used by a customer is prop-erly labeled as to:

• Contents• Hazard warning• Name of manufacturer or other responsible party

The manufacturer, importer, or distributor is also requiredto provide, upon request, any additional information re-quested about a specific hazardous material. A chemicalmanufacturer, however, may declare the ingredients of acompound a “trade secret”. In this case, if an accidentoccurs where this information is vital, the manufacturer isrequired to relinquish all information. The assumption isthat the trade secret in question will not be divulged.

The employer is required to maintain all labels on thecontainers. Labels should be legible, in English, andprominently displayed or readily available.

Labeling Systems

There are several labeling systems approved for use inindustrial settings. The three most common labelingsystems are the:

• HMIS• NFPA• DOT system



Hazardous MaterialIdentification System (HMIS)

The HMIS (designed by the National Paint and CoatingAssociation) is a comprehensive system for hazardousmaterials identification. This system conveys chemicalidentity by chemical or common names, code numbers, orother descriptive terms which clearly identify the material.The acute health, flammability, and reactivity hazards arecommunicated by numerical ratings inserted onto the labelitself. The description of the numerical Hazard Index (HI)is shown as follows:

4 Extreme Hazard3 Serious Hazard2 Moderate Hazard1 Slight Hazard0 Minimal Hazard

These designations will be written with indelible ink oneach section of the label (Health, Flammability, Reactivity).Information is obtained from the MSDS or other sourcesacceptable to OSHA.

Health Hazard or Blue Section

4 Extreme Highly Toxic - May be fatal onshort term exposure. Specialprotective equipment required.

3 Serious Toxic - Avoid inhalation or skincontact.

2 Moderate Moderately Toxic - May beharmful if inhaled or absorbed.

1 Slight Slightly Toxic - May cause slightirritation.

0 Minimal All chemicals have some degreeof toxicity.



Fire Hazard or Red Section

4 Extreme Extremely flammable gas orliquid, Flash Point below 73° F.

3 Serious Flammable - Flash Point 73° F to100° F.

2 Moderate Combustible - Requires moderateheating to ignite. Flash Point100° F to 200° F.

1 Slight Slightly Combustible - Requiresstrong heating to ignite.

0 Minimal Will not burn under normalconditions.

Reactivity Hazard or Yellow Section

4 Extreme Explosive at room temperature.

3 Serious May explode if shocked, heatedunder confinement or mixed withwater.

2 Moderate Unstable, may react if mixedwith water.

1 Slight May react if heated or mixedwith water.

0 Minimal Normally stable, does not reactwith water.

Personal Protective Equipmentor White Section

Recommended personal protective equipment (PPE) isidentified in this section by a letter. The white bar indicateswhat Personal Protection to use when handling the mate-rial. Letters A through K correspond to a variety of protec-tive ensembles. A chart listing these ensembles must bereferenced. If PPE requirements are uncertain or assistanceis needed, see the MSDS.



National Fire ProtectionAssociation (NFPA) Diamond

The NFPA Diamond is a labeling system that incorporatesthe use of four diamonds combined in one central diamond.NFPA 704 M is a standardized system that uses numbersand colors to define the hazards of a material. The dia-mond-shaped design displays four color and hazard combi-nations similar to the HMIS systems:

• Health (blue)• Flammability (red)• Reactivity (yellow)• Special Information (white)

To indicate the degree of the hazard presented by thematerial, the numbers from 0 - 4 are used. The numberfour (4) indicates the maximum or most severe hazard.NFPA ratings for individual chemicals can be found in theNFPA “Guide to Hazardous Materials”.

Health Hazard or Blue Section

4 Deadly3 Extreme Danger2 Hazardous1 Slightly Hazardous0 Normal Material



Flammability Hazard of Red Section

4 Flash Point below 73° F.3 Flash Point below 100° F.2 Flash Point above 100° F, not exceeding

200° F.1 Above 200°F.0 Will Not Burn.

Reactivity Hazard or Yellow Section

4 May Detonate3 Shock and Heat May Detonate2 Violent Chemical Change1 Unstable If Heated0 Stable

Special Information or White Section

The white part of the NFPA diamond is for special informa-tion about a specific hazard. You may find the following inthe white block:

OX = OxidizerW = Use no waterACID = AcidALK = AlkaliCOR = Corrosive



U. S. Department ofTransportation (DOT)

Hazard Identification System

The U. S. DOT’s Hazardous Materials TransportationAdministration regulates over 1,400 hazardous materials.The DOT requires labels on small containers and placardson tanks and trailers. These placards and labels indicate thenature of the hazard.

Classification used for placards and labels is based on anInternational Classification System. Materials are de-scribed using hazard class numbers that are found in thebottom corner of a DOT placard or label. The DOT num-bering system has no relationship to the NFPA or HMISnumbering systems!

To facilitate handling a hazardous material incident, plac-ards may show a 4-digit identification number. This num-ber comes from the Hazardous Materials Table in the DOTregulations, 49 CFR 172.101. This ID number can befound on shipping papers, the hazardous waste manifest,and hazardous waste markers. Once the 4-digit number isobtained, the North American Emergency Response Guide-book can be consulted. This book outlines recommendedmethods and precautions for responding to a release of eachhazardous materials with a 4-digit ID number.

Material Safety Data Sheets

Chemical manufacturers and importers are required toobtain or develop Material Safety Data Sheets (MSDSs)and supply them to the employer.

The employer is required to have MSDSs available for allhazardous chemicals used in the work place and must makethem available to all employees during all work shifts.



OSHA mandates that the following information be in-cluded on all MSDSs:

• Identity of chemical(s)• Permissible exposure levels• Precautions to prevent injury• Personal protective equipment• Control measures to reduce exposure

Additional information on an MSDS may include:

• Chemical properties• Environmental concerns• Transportation concerns• Packaging and storage guidelines• First aid and emergency treatment

Currently, OSHA is trying to adopt the ANSI standard onMSDSs. This standard will require a consistent layout ofMSDSs including information presented in the samesection and the same order on all MSDSs, regardless of theproduct manufacturer.



Pre-Incident Planning

As we have seen in the previous sections of this chapter, theDOT, OSHA, and EPA have many regulatory requirements,many of which appear to overlap. Yet the agencies requireseparate and distinct reporting requirements, labels, ship-ping papers/hazardous waste manifests, and emergencyplans.

Pre-planning is nothing new to the fire service. Mostdepartments conduct in-service pre-plan activities on aroutine basis. These pre-plans have traditionally addressedinformation such as building contacts, utilities shut-offs,type of construction, and resources (i.e. water, engines,ladders) needed to control a fire incident involving thebuilding.

This section does not address the basic pre-plan informa-tion; instead, it addresses some of the new regulations thatindustry must comply with, and how these regulations willactually assist the fire service. This section will alsoprovide some sample forms which you can use or modify tofit your department’s needs.

SARA Requirements

As we discussed in the OSHA section of this module, theSARA Title III regulation was a major asset for the fireservice community. This regulation made facilities complywith Emergency Planning notifications, designate facilityemergency coordinators, make notification in the event of arelease of a chemical, and provide information to respond-ers such as MSDSs. SARA Title III also required statesand local authorities to conduct emergency planning forSERCs and LEPCs respectively.



Final Rules

Integrated Contingency Plan

In addition to SARA requirements, other federal agenciesrequire plans to be written. Two fairly recent final rulespublished in the Federal Register are going to make haz-ardous materials pre-planning for the fire service mucheasier.

The first rule, titled “The National Response Team’sIntegrated Contingency Plan Guidance” is a collaborativeeffort of the following agencies:

• Department of Transportation• Coast Guard• Research and Special Programs Administration

(RSPA)

• Department of the Interior• Mineral Management Service

• Department of Labor• Occupational Safety and Health Administration

(OSHA)

This guidance, also known as the Integrated ContingencyPlan (ICP) or “One-Plan” allows a facility to write oneplan and comply with the written plan requirements fromall of the above listed agencies. The Federal Registersummarizes the one-plan as follows “...this guidance isintended to be used by facilities to prepare emergencyresponse plans. The intent of the NRT is to provide amechanism for consolidating multiple plans that facilitiesmay have prepared to comply with various regulations intoone functional emergency response plan or integratedcontingency plan.”

This plan will give the hazardous materials respondersvaluable information regarding the types and quantities ofmaterials on site, the facility’s response capabilities, andany equipment on site or through contractors which isavailable for use to control a release from the facility.



Risk Management Plan

The second rule, titled “Accidental Release PreventionRequirements: Risk Management Programs Under theClean Air Act, Section 112 (r) (7);...” will address veryspecific facilities which use and store certain materials.This plan, based on the CAA Amendments of 1980, states“The intent of section 112 (r) is to prevent accidentalreleases to the air and mitigate the consequences of suchreleases by focusing prevention measures on chemicals thatpose the greatest risk to the public and the environment.”

The Risk Management Program requires stationary sourcesto develop and implement a risk management programwhich includes a hazard assessment, prevention program,and an emergency response program. The risk manage-ment program must be submitted to the EPA in the form ofa Risk Management Plan (RMP). This plan must also besubmitted to state and local authorities and made availableto the public.

The main component of the RMP is to evaluate Worst CaseScenarios (WCS) involving the release of a regulatedsubstance. The WCS is defined “...as the release of thelargest quantity of a regulated substance from a vessel orprocess line failure, including administrative controls andpassive mitigation that limit the total quantity involved ofthe release rate. For most gases, the WCS assumes that thequantity is released in ten minutes. For liquids, the sce-nario assumes an instantaneous spill.” In addition to thegas release, if the material is flammable, the WCS includesa resulting vapor cloud explosion and fire ball effects to thesurrounding community.

The RMP is a complex document which includes vulner-able populations, off-site consequences of the release, theconcentrations of materials released at downwind distances,and the available facility control method which may limitor prevent these releases. One of the most common materi-als on this list is propane. Facilities which store 10,000 lbs.of propane, even if it is used to heat the building, will needto develop an RMP.



In the final guidance, the “EPA encourages local emergencyplanners, fire departments, and others who use tools such asCAMEO/ALOHA or other modeling techniques to assistbusinesses in their community who may need help in theirmodeling efforts.”

Due to this rule, industry may be turning to the fire serviceto assist in planning the response to the Worst Case Sce-nario at a facility. Imagine if the information contained inthe RMP was available to the local hazardous materialsresponse team and the local fire department prior to anincident at the facility. This pre-planning tool will be avaluable asset to all first responders.

The RMP requirements are complex and will requireindustry to work with the local jurisdiction in developingthe RMP and associated emergency response plans forthose incidents. This plan, coupled with the “One-Plan”discussed earlier, will give first responders and hazardousmaterials teams a tremendous amount of information to aidin incident mitigation and help assure the safety of respond-ers, the public, and the environment.



Application Exercise





Application Exercise

You will need:

• An assortment of drums, boxes, glass bottles, wooden crates, or other types of containersthat could be used for hazardous materials

• DOT placards/labels or NFPA or HMIS markings (preferably for some incompatiblechemicals)

• MSDSs for one or two of the “chemicals” in the containers

• One or two completed shipping papers to accompany some or all of the containers (somemay be incorrectly or incompletely filled out)

• North American Emergency Response Guidebooks

• Hazardous Materials Table (49 CFR 172.101)—optional

Preparation

This exercise is intended to help students become more familiar with recognizing hazardousmaterials in storage and transportation situations. Stage an “incident” (set up on a road or in afixed location) and position the containers around the scene. Open some of them to simulate abreach.

Briefly describe the “incident” and assign groups of students to fill the roles of the first-in enginecompany, the hazardous materials team, and the incident commander. Initially, give the studentsonly the information they would be told by the dispatcher. As the incident progresses, providethe students with the additional information they might find at an actual scene, such as theshipping papers or MSDSs.

As the students work through the exercise ask the following questions, focusing on regulationsthat would apply to this incident. Include additional questions appropriate to your jurisdiction.

1. What initial actions would you take? (first-in company)2. What personal protective equipment would you wear? (first-in company)3. What resources would you call for? (incident commander)4. What initial actions would you take? (hazardous materials team)5. What personal protective equipment would you wear? (hazardous materials team)6. What follow-up/mitigating actions would you take? (both teams)7. Which agency’s regulations apply to this scene?8. Which specific regulations apply to this scene?9. What are the types of hazards? (e.g. safety, chemical, physical, health)



10. What type of industry might use each of these materials?11. Using the Hazardous Materials Table as a reference, is each of the chemicals packaged

correctly? (optional)12. Using the Segregation Table in your Student Text, are there any materials that should not

be stored or transported together?13. Are there any conflicts between information on the placards/labels/markings, and the

MSDSs or shipping papers?14. Who would be responsible for clean-up and disposal of these chemicals?



Action Statement





Action Statement

You have just completed the first module of the Hazardous Materials Technician course. Thetopics included:

• The structure of the Code of Federal Regulations (CFR)• The function of the Department of Transportation (DOT) in regulating hazardous

materials• The function of the Occupational Safety and Health Administration (OSHA) in regulating

hazardous materials• The function of the Environmental Protection Agency in regulating hazardous waste• The purpose of the Resource Conservation and Recovery Act (RCRA)• Methods of identifying hazards• Pre-incident planning

Knowing how you respond to emergencies in your first due areas, would you change your actionsor habits based on the information covered in this module? Listed below are some suggestedactions. Some you may already do, and others may not fit your work environment. If there areactions you have not done in the past, do you think you will begin doing them as a result of thistraining?

1. Look for and interpret DOT placards and labels and other markings at the scene of ahazardous materials incident.

2. Read shipping papers with a more thorough understanding of the important information.3. Recognize when certain classes of hazardous materials should be separated during trans-

portation or storage.4. Find out more about ways to protect myself by becoming familiar with applicable OSHA

regulations, such as the standards on confined space or bloodborne pathogens.5. Obtain and review the facility’s Integrated Contingency Plan (ICP) or Risk Management

Program (RMP) when preparing a pre-incident plan.6. (Create my own action statement.)

_________________________________________________________________________

_________________________________________________________________________

________________________________________________________________________

________________________________________________________________________





Appendix A

Activities





Hazardous Materials Table Activity 1

Given the Hazardous Materials Table, complete the following activities:

1. What hazard class is associated with nitroglycerin mixture?

2. Which packing group includes paint?

3. Name the primary and two subsidiary hazard labels used when shipping nitric acid, RedFuming.

Primary Label ____________________Subsidiary Label ____________________

4. When shipping sulfuric acid by highway in 55-gallon containers, what specialprovision(s) apply?





Oxidizer Case Study Activity 2

May 25, 199011:00 a.m.

First responding fire fighters are called to a reported fire on an interstate highway. The initialresponse includes two engine companies, two EMS units, a heavy rescue squad and a battalionfire chief. Units can see a large column of smoke in the sky as they approach the reported loca-tion.

Traffic is at a standstill in the northbound lanes where the incident is occurring and movingslowly in the southbound lanes as cars slow to observe the incident. The air temperature is 85°F,it is a partly cloudy day, and there is light wind blowing out of the west.

Exposures include a residential neighborhood and a large high school one-quarter mile east ofthe incident location.

The first engine company on the scene reports a straight-body truck on the shoulder of thenorthbound lanes with the cargo compartmen involved in fire. The driver meets the enginecompany officer as they stop upwind and about 500 feet from the burning vehicle.

The driver reports that the vehicle is carrying about a dozen containers of potassium permangan-ate for a total weight of 800 lbs. The UN number of the shipment is 1490. It appears that the firemay be caused by hot brakes on the rear of the vehicle and while you are gathering information,the fire begins to intensify, creating a large plume of heavy white and black smoke and a series ofsmall explosions.

The engine company approaching from the north slowly drives through the smoke/vapor plume.

Briefly discuss how your hazardous materials team would carry out the following activities:

ResearchConfirm site control and confirm zonesComplete size-upCreate action planCreate necessary sectors: HM, OPS, Staging, EMS, and RehabGather sourcesInitiate limited evacuationBegin fire fighting actions using remote streamsDecontaminate exposed first respondersProvide for remote containment runoffStabilize post-fire incidentPlan for hand-off and termination





Hazard Class Activity 3

1. A division 4.2 material isa. Dangerous When Wetb. Oxidizerc. Spontaneously Combustible

2. A division 5.1 material is:a. Organic Peroxideb. Oxidizerc. Ignitable Metal Powders

3. A Class 3 (flammable liquid) has a flash point of less than °F.

4. T or F: Division 6.1 materials may sometimes be poison by inhalation.

5. T or F: Human blood is a Division 6.2 material.

6. T or F: The activity level of a Class 7 - Radioactive material is measured before thematerial is packaged.

7. What is the hazard class number for materials which destroy steel containers?_____

8. Circle the LEAST hazardous packing group. I II III

9. List the nine HM-181 hazard classes and describe each briefly.

10. Given the following table, circle the hazard class and highlight the packing group associ-ated with each entry.

11. Hazard zones are associated with two types of hazardous materials. What are thesetypes?

Acetone, 3, UN 1090, PG II

RQ Environmentally Hazardous Substance, liquid n.o.s., 9,UN 3082, III (PCBs or Polychlorinated Biphenyls)

Sulfuric Acid, 8, UN1830, II





Labeling and Marking Activity 4

1. Required labels are specifired in Column of the Hazardous Materials Table.

2. What does DOT-E mean?

3. Inhalation hazard markings are required for Division materials and Division materialsthat are poisonous by inhalation.

4. Look up the methyl vinyl ketone in the Hazardous Materials Table.

a. What is the primary hazard label?

b. What are the subsidiary hazard labels?

5. The requires marking and labeling on containers of Hazardous Materials.

6. An outer package that contains an inner package is called a package.

7. Non-bulk packaging with inner packaging containing liquid hazardous materials must be packedwith closures up and marked with or .





Segregation Table Activity 5

1. True / False Oxidizers and materials that are Dangerous When Wet can be shippedtogether without segregation.

2. True / False Corrosives and materials that are Poison by Inhalation can be shippedtogether.

3. True / False Ammonia nitrate can be stored with Explosives 1.1.

4. True / False Spontaneously Combustible materials can be transported with FlammableGases.

5. True / False Organic Peroxides must be segregated when stored with FlammableGases.

6. True / False Corrosive Liquids must be segregated when shipped with FlammableLiquids.

7. True / False Radioactive materials must be segregated when shipped with FlammableGases.

8. True / False Poison Gas (other than Zone A) can be shipped with materials that areDangerous When Wet.





Regulatory Agency Activity 6

For each of the acronyms below, identify the letters, name the responsible regulatory agency, andmatch the acronym to its appropriate definition.

1. RCRA:Responsible Agency:Definition:

2. 49 CFR:ResponsibleDefinition:

3. 29 CFR 1910.1200:Responsible Agency:Definition:

4. CAA:Responsible Agency:Definition:

5. CERCLA:Responsible Agency:Definition:

6. 29 CFR 1910.1030:Responsible Agency:Definition:

7. SARA Title III:Responsible Agency:Definition:

Definitions:A. The first comprehensive federal effort to deal with solid and hazardous waste.B. Helps prevent or minimize pollution.C. Gives the federal government the authority to respond to environmental hazards posed by

abandoned disposal sites.D. Also known as the Emergency Planning and Community Right-to-Know Act.E. Includes all U.S. DOT regulations.F. Covers occupational exposure to potentially infectious materials.G. Deals with hazardous waste operations and emergency response.H. Requires employers to identify hazards in their workplaces.





Appendix B

29 CFR 1910.120 Summary





29 CFR 1910.120 Summary

Paragraph B - The Safety and Health Plan. A written health and safety program is requiredfor employees involved in hazardous waste operations. The program will be designed to identify,evaluate and control safety and health hazards, and provide for emergency reponse for hazardouswaste operations.

Paragraph C - Site Characterization. Identification of specific site hazards are required andthe appropriate safety and health control procedures are needed to protect the employee.

Paragraph D - Work Site Control. Site control procedures are to be implemented for thepurpose of controlling employee exposure to hazardous substances before clean-up operationsbegin.

Paragraph E - Training Requirements for Site Workers. The amount of training an employeeshall receive before working on a site is detailed herein. Paragraph E also indicates the type oftraining and certification needed to work on a clean-up site where employees may be exposed tohazardous substances and safety or health hazards.

Paragraph F - Medical Surveillance. Since only specific employees are covered under thisparagraph, they are clearly identified here. The frequency of medical examinations and consulta-tions; the content of medical examinations and consultations; examination costs; type of physi-cian; information given to the physician; the report issued following the exam called thephysician’s written opinion; and record keeping requirements.

Paragraph G - Engineering Controls, Work Practices, Personal Protective Equipment.Engineering controls, work practices, and personal protective equipment necessary to protectemployees from exposure to hazardous substances are outlined in paragraph G. The purpose ofthis paragraph is to protect employees from safety and health hazards.

Paragraph H - Monitoring. Air monitoring is discussed herein. Requirements such as when isair monitoring to be used and how often should air monitoring take place are detailed in para-graph H.

Paragraph I - Informational Programs. Paragraph I describes programs designed to informemployees, contractors, and subcontractors of the nature, level, and degree of exposure thatcould result from working on a site.

Paragraph J - Drum and Container Handling. Paragraph J describes how hazardous sub-stances, contaminated soils, liquids and other residues are to be handled, labeled, stored, andtransported. Possible ergonomic injuries should also be considered.

Paragraph K - Decontamination. Paragraph K describes the phases of decontamination suchas procedures, location or set-up, equipment required, solutions used, and PPE



Paragraph L - Emergency Response at Uncontrolled Hazardous Waste Sites. This para-graph describes the emergency response plan, elements of the emergency response plan, andprocedures for handling emergency incidents.

Paragraph M - Illumination. The requirements for minimum illumination are described in thisparagraph.

Paragraph N - Sanitation. Paragraph N describes sanitation requirements at temporary workplaces which include potable and non-potable water, toilet facilities, food handling, washingfacilities, and shower and change rooms.

Paragraph O - New Technology Programs. Paragraph O describes new technology, equip-ment, and programs to be developed for the improved protection of employees working at haz-ardous waste clean-up sites.

Paragraph P - Operations Conducted Under RCRA. Paragraph P describes the programsrequired for workers who are employed at treatment, storage and disposal (TSD) facilities. Theseprograms include:

A. Safety and Health ProgramB. Hazard Communication ProgramC. Medical Surveillance ProgramD. Decontamination ProgramE. New Technology ProgramF. Material Handling ProgramG. Training Program - Initial training shall be for 24 hours and a refresher training

of eight hours annually. A written certificate shall be given to show successfulcompletion of the training.

H. Emergency Response Program with the following elements included:Pre-Emergency Planning and coordination with outside parties;Personnel roles, lines of authority and communication;Emergency recognition and prevention;Safe distances and places of refuge;Site security and control;Evacuation routes and procedures;Decontamination procedures;Emergency medical treatment and first aid;Emergency alerting and response procedures;Critique of response and follow-up; andPPE and emergency equipment.

In addition to the above elements, the ERP must also have details about trainingand procedures for handling emergency incidents.



Appendix C

State Plan and Non-State Plan States





State Plan States

All paid employees—private sector and federal and local public sector employees—in the fol-lowing states/territories are covered by their state’s worker protection plans.

AlaskaArizonaCaliforniaConnecticut (for state and local government employees only)HawaiiIndianaIowaKentuckyMarylandMichiganMinnesotaNevadaNew MexicoNew York (for state and local government employees only)North CarolinaOregonPuerto RicoSouth CarolinaTennesseeUtahVermontVirginiaVirgin IslandsWashingtonWyoming



Non-State Plan States

State and local government employees of the following states are covered by the EPA worker protectionregulations. Private sector and federal fire fighters in the following states/territory are covered by federalOSHA worker protection regulations.

Alabama MissouriArkansas MontanaColorado NebraskaDelaware New HampshireDistrict of Columbia New JerseyFlorida North DakotaGeorgia OhioGuam OklahomaIdaho PennsylvaniaIllinois Rhode IslandKansas South DakotaLouisiana TexasMaine West VirginiaMassachusetts WisconsinMississippi



Appendix D

Sample Material Safety Data Sheet and MSDS Checklist





MDSD—Toluene

RANDOLPH PRODUCTS — TOLUENEMATERIAL SAFETY DATA SHEETFSC: 6810NIIN: 00F000177Manufacturer’s CAGE: 77672Part No. Indicator: APart Number/Trade Name: TOLUENE=========================================================================== General Information===========================================================================Item Name: /Company’s Name: RANDOLPH PRODUCTS CO.Company’s Emerg Ph #: 201/438-3700Record No. For Safety Entry: 001Tot Safety Entries This Stk#: 001Date MSDS Prepared: 01JAN85Safety Data Review Date: 20APR84MSDS Serial Number: BBGBJ=========================================================================== Ingredients/Identity Information===========================================================================Proprietary: NOIngredient: TOLUENE (SARA III)Ingredient Sequence Number: 01Percent: 100NIOSH (RTECS) Number: XS5250000CAS Number: 108-88-3OSHA PEL: 200 PPM/150 STELACGIH TLV: 50 PPM; 9293=========================================================================== Physical/Chemical Characteristics===========================================================================Boiling Point: 230FVapor Density (Air=1): >AIREvaporation Rate And Ref: <1 ETHER=1Percent Volatiles By Volume: 100=========================================================================== Fire and Explosion Hazard Data===========================================================================Flash Point: 41F T.C.C.Lower Explosive Limit: 1.2Extinguishing Media: SAND, FOAM, CO2Special Fire Fighting Proc: DRY CHEMICALS, FOAMUnusual Fire And Expl Hazrds: NONE=========================================================================== Reactivity Data===========================================================================Stability: YESCond To Avoid (Stability): FLAMEHazardous Poly Occur: NO



=========================================================================== Health Hazard Data===========================================================================Signs/Symptoms Of Overexp: VAPORS MAY CAUSE DROWSINESS, HEADACHE,DIZZINESS AND IRRITATION OF EYES, NOSE AND THROATEmergency/First Aid Proc: REMOVE TO FRESH AIR, FLUSH EYES WITH LOTS OFWATER, CONSULT PHYSICIAN.=========================================================================== Precautions for Safe Handling and Use===========================================================================Steps If Matl Released/Spill: REMOVE ALL SOURCES OF IGNITION, WEARAPPROVED RESPIRATOR, CONTAIN SPILL WITH INERT SSTANCE (SAND, DIRT), PUTMIXTURE IN CONTAINERS FOR DISPOSAL. KEEP SPILL T OF SEWERS AND OPEN BODIESOF WATER.Waste Disposal Method: LAND FILL—ACCORDING TO CURRENT LOCAL, STATE ANDFEDERAL REGULATIONS.Precautions-Handling/Storing: KEEP AWAY FROM HEAT, FLAME. KEEP AWAY FROMCHILDREN.=========================================================================== Control Measures===========================================================================Respiratory Protection: MESA/NIOSH APPROVED RESPIRATOR WHERE VAPORCONCENTRATES.Ventilation: EXPLOSION-PROOF EXHAUST VENTILATION AT POINT OF RELEASESuppl. Safety & Health Data: PARK PLACE EAST CARLSTADT, NJ 07072=========================================================================== Transportation Data====================================================================================================================================================== Disposal Data===========================================================================Disposal Data Review Date: 88055Rec # For This Disp Entry: 01Tot Disp Entries Per NSN: 001Landfill Ban Item: YESDisposal Supplemental Data: PARK PLACE EAST CARLSTADT, NJ 07072 IN CASE OFACCIDENTAL EXPOSURE OR DISCHARGE, cONSULT HEALTH AND SAFETY FILE FORPRECAUTIONS.1st EPA Haz Wst Code New: U2201st EPA Haz Wst Name New: TOLUENE; METHYLBENZENE1st EPA Haz Wst Char New: TOXIC (T)1st EPA Acute Hazard New: NO2nd EPA Haz Wst Code New: D0012nd EPA Haz Wst Name New: IGNITIBLE2nd EPA Haz Wst Char New: IGNITABILITY2nd EPA Acute Hazard New: NO



=========================================================================== Label Data===========================================================================Label Required: YESLabel Status: GCommon Name: TOLUENESpecial Hazard Precautions: VAPORS MAY CAUSE DROWSINESS, HEADACHE,DIZZINESS AND IRRITATION OF EYES, NOSE AND THROATLabel Name: RANDOLPH PRODUCTS CO.Label Emergency Number: 201/438-3700





MSDS Checklist

Hazardous Material:Shipping Name:___________________________________ DOT Hazard Class:______________Chemical Name:__________________________________ ID #:__________________________

Physical Description:Normal Physical Form: Solid / Liquid / GasColor:________________________________ Odor:____________________________________Other:________________________________

Chemical Properties:Specific Gravity:_________________ Vapor Pressure:________________ Vapor Density:__________Boiling Point:___________________ Melting Point:___________________Soluble in Water: Yes / No Degree:_________________________Other:______________________________________________________________

Health Hazards:Inhalation Hazard: Yes / NoPEL:____________ TLV/TWA:_____________ IDLH:______________LC

50:_________________

Ingestion Hazard: Yes / NoLD

50:___________________ mg/kg

Absorption Hazard: Yes / NoSkin:____________ Eyes:__________________Carcinogen: Y / N Mutagen: Y / N Teratogen: Y / NHazardous to Aquatic Life: Y / NOther:____________________________________________________________________________

Decon Procedures:_________________________________________________________________________First Aid:_________________________________________________________________________________

Fire Hazards:Flash Point::_____________ LEL:_____________ UEL:_________ Ign. Temp.:_____________Toxic products of combustion:________________________________________________________Other:___________________________________________________________________________Extinguishing agents:_______________________________________________________________

Reactivity Hazards:Reactive with:______________________________________________________________________

Corrosivity Hazards:pH:__________ Corrosive to: Skin /Steel/Other:___________________________________Neutralizing Agents:_________________________________________________________________

Radioactive Hazards:Alpha / Beta / Gamma Other:______________________________________________________

Recommended Protection:Public: Evac Distance_______________________Response Personnel: Level of protection:______________Compatible material(s):_________________________Environment:_____________________________________________________________________



Documents

Module 1: Regulations - International Association of Fire … Module 01 Student Text.pdf · · 2007-04-04Quiz at the beginning of this module. ... Safety and Health Act? A. OSHA