Frequently Asked QuestionsAnswers to the most commonly asked questions
Member of the Midwest Hazardous Waste Workers
Training Program of the University of Cincinnati.
Funded by the National Institute of
Environmental Health Sciences (NIEHS).
First, we must make certain that we are referring to the correct regulatory category among the many definitions using the key word hazardous. Let’s look at the use of the word hazardous in the regulations.
- Hazardous Substance
- Hazardous Material
- Hazardous Waste
- Hazardous Drugs
- Bio-hazardous Waste
As you can see, there are many categories regulated as “Hazardous.” for our purposes, we’ll be referring to “Hazardous Materials”
What are Hazardous Materials?
Hazardous Materials are any item or agent (biological, chemical, radiological, and/or physical), which has the potential to cause harm to humans, animals, or the environment, either by itself or through interaction with other factors. Hazardous materials professionals are responsible for and properly qualified to manage such materials. This includes managing and/or advising other managers on hazardous materials at any point in their life-cycle, from process planning and development of new products; through manufacture, distribution and use; and to disposal, cleanup and remediation.
Who decides what is a “hazardous material?”
Hazardous materials are defined and regulated in the United States primarily by laws and regulations administered by the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA), the U.S. Department of Transportation (DOT), and the U.S. Nuclear Regulatory Commission (NRC). Each has its own definition of a “hazardous material.
- OSHA’s definition of a hazardous material includes any substance or chemical which is a “health hazard” or “physical hazard,” including: chemicals which are carcinogens, toxic agents, irritants, corrosives, sensitizers; agents which act on the hematopoietic system; agents which damage the lungs, skin, eyes, or mucous membranes; chemicals which are combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive; and chemicals which in the course of normal handling, use, or storage may produce or release dusts, gases, fumes, vapors, mists or smoke which may have any of the previously mentioned characteristics. (Full definitions can be found at 29 Code of Federal Regulations (CFR) 1910.1200.)
- EPA’s definition of a hazardous material incorporates the OSHA definition and adds any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment. (40 CFR 355 contains a list of over 350 hazardous and extremely hazardous substances.)
- DOT’s definition of a hazardous material is any item or chemical which, when being transported or moved in commerce, is a risk to public safety or the environment, and is regulated as such under its Pipeline and Hazardous Materials Safety Administration regulations (49 CFR 100-199), which includes the Hazardous Materials Regulations (49 CFR 171-180). In addition, hazardous materials in transport are regulated by the International Maritime Dangerous Goods Code; Dangerous Goods Regulations of the International Air Transport Association; Technical Instructions of the International Civil Aviation Organization; and U.S. Air Force Joint Manual, Preparing Hazardous Materials for Military Air Shipments.
- The NRC regulates materials considered hazardous because they produce ionizing radiation, which means those materials that produce alpha particles, beta particles, gamma rays, x-rays, neutrons, high-speed electrons, high-speed protons, and other particles capable of producing ions. This includes “special nuclear material,” by-product material, and radioactive substances. (See 10 CFR 20).
Why is the classification of a hazmat so important?
Hazmat can pose a significant safety risk while in transportation. DOT has carefully designed specific packaging, marking, and labeling requirements to ensure proper handling and safe transport. These requirements can vary between different hazard classifications, so it is imperative to first correctly identify the hazard posed by the material you plan to ship.
Hazmat transportation requirements are tailored to the risks presented by each material. You need to know what you are shipping before you can properly contain the hazmat and communicate its risk.
How do I classify a product as hazmat?
Often, the best way to obtain the correct hazard classification of a consumer product is by locating the Safety Data Sheet (SDS) from the manufacturer. The DOT hazmat regulations provide classification criteria that manufacturers, shippers, and others can use to classify hazardous material. Certain types of hazmat require PHMSA’s approval of the classification determination prior to shipment (e.g., explosives).
Are there any exceptions to hazmat transportation regulations?
Depending on the type of hazmat, quantities in a package, or mode of transportation, there are many exceptions to certain hazmat transportation regulations. Consumer products may qualify for exceptions from hazmat transportation regulations. If you need help identifying an exception in the regulations, be sure to contact the Hazardous Materials Information Center. The Hazardous Materials Information Center is available by telephone (1-800-467-4922 or 202-366-4488) Monday through Friday from 9 am – 5 pm EST or anytime by e-mail (email@example.com)!
What is the difference between hazardous materials and dangerous goods?
The term “hazardous materials” is primarily used in the United States for materials that are subject to the DOT hazardous materials regulations. The term “dangerous goods” is used internationally for materials that are subject to the international regulations. Because the US DOT rules incorporate the United Nations Recommendations for the Transport of Dangerous Goods, most dangerous goods are also DOT hazardous materials. But there are significant differences that you must be aware of which are covered in Environmental Resource Center’s training.
Who needs OSHA Hazard Communication Training?
Hazard communication training is required for employees who work with or are exposed to hazardous chemicals (any chemical required to have a Safety Data Sheet). Employees must be trained before working with hazardous chemicals, and their training must be updated whenever they are required to work with new hazards that were not part of the scope of their prior training.
Who needs Hazwoper Training?
Any employees who respond to releases or potential releases of hazardous substances for the purpose of stopping, containing and cleaning up the release must be trained to HAZWOPER technician level. They must receive at least 24 hours of training that covers key topics that will ensure they respond to hazardous substance releases safely and properly.
Personnel who perform cleanup operations at waste sites – including Superfund sites, RCRA corrective action sites, or even voluntary cleanup sites – must complete 40 hours of initial classroom instruction that covers key topics required by the HAZWOPER standard.
Eight hours of annual refresher training is required for waste site cleanup workers and workers at hazardous waste treatment, storage and disposal facilities. Emergency responders at other sites must have annual training of sufficient duration and content to maintain their competencies.