By Brian J. Riker
When you think of hazardous materials you often think of things like explosives, corrosives, marine pollutants or even radioactive material. Things that are unusual or pose an extraordinary risk to the health and safety of the public. Maybe even large quantities of gasoline, such as in a tanker trailer. But, what about the things you use in everyday life?
As a tower you are often called upon to perform some basic roadside assistance or perform light mechanical repairs to help get your customers back on the roadway. You most likely even carry a few items in your truck just to maintain it in good working order.
Many of these everyday items are hazardous materials, class 9 ORM-D, meaning consumer quantity of hazardous substances that do not require specialized training or handling.
Everyday Items That Count as Hazmat
Things like a can of WD-40, spray paint for touching up the under lift (if you know, you know) or even windshield washer fluid, motor oil and the spare batteries for your impact gun.
These are all routine class 9 ORM-D materials that we don’t think twice about, yet, when transported in a commercial vehicle there are certain regulations that must be followed.
What about gasoline? Yes, everybody knows, or should know, that gasoline is extremely flammable and dangerous, yet it is also a routine part of nearly everybody’s day, so safety often gets overlooked.
Defining “Materials of Trade”
Ultimately, all the above items, and more, are considered Materials of Trade by the US Department of Transportation’s Pipeline and Hazardous Materials Administration when carried to support operation of your truck or to provide service to your customers.
As such, there are strict regulations on the individual quantity that can be carried, the aggregate quantity and even how these materials may be transported in, or upon, a commercial motor vehicle.
Below is a quick summary of the rules. See 49 CFR Parts 171-180 (HMR) for detailed information.
Know Your Responsibilities
Be aware that it is your responsibility to know if you are transporting hazardous materials and the requirements that apply. You must have general knowledge of the regulations, understand the quantity limitations, packaging requirements and how these materials need to be labeled and marked.
Fortunately, these rules are simplified, and when legally transporting Materials of Trade, you do not need shipping papers, emergency response information, placarding, formal training or a hazmat endorsement.
Size and Weight Limits
For most towing and road service operations the important size limits include:
-- No more than 8 gallons of flammable liquid per container
-- Gas cylinders (like Oxygen and Acetylene) cannot exceed 220 pounds
-- Aerosol spray cans are permitted if the cap is tight, the label is clean and clear, and they are secured from free movement
-- The aggregate total weight of all these materials combined cannot exceed 440 pounds.
Packaging and Marking Requirements
Materials of Trade also have packaging and marking requirements that help increase safety.
The packaging must be the manufacturer’s original packaging or a package of equal or greater strength and integrity. The packaging must be marked with a common name (such as “gas” or “spray paint”) or a proper shipping name from the Hazardous Materials Regulations (such as “Isopropyl Alcohol”).
Packaging must be leak tight for liquids and gases, and sift proof for solids. Packages must be securely closed, secured against movement, and protected against damage.
Gasoline must be transported in a metal or plastic container meeting DOT or OSHA requirements. Several states also have specific rules about gasoline containers, so be sure that your containers are also state approved.
Inspections and Compliance
In a typical roadside inspection, the inspector will:
-- Ask leading questions to make sure the driver understands the risks of the materials they are transporting
-- Check that they are secured and in the proper containers or packages
-- Ensure they are not leaking and properly marked
-- Verify that the total of all Materials of Trade does not exceed 440 pounds
Special Note on Waste Materials
Lastly, it is important to note that waste, such as used motor oil, is not considered a material of trade and therefore is not covered under these regulations nor is it counted towards the 440-pound aggregate total.
Be sure you are properly transporting your waste products, especially in your mobile service rigs. That tank of used motor oil needs to be labeled, secured and you should be prepared to test the flash point (under 140 degrees F) upon request to prove it is not actually flammable.
