MOVING INVENTORY
PART 2
“No person may offer or accept a hazardous material for transportation in com- merce unless that person is registered in conformance with the rule as defined in 49 CFR 171.2(a) subpart G of Part 107 of this chapter,
DOT regulations require that HazMat Employers train, test, and maintain test records for all HazMat Employees.
if applicable, and the hazardous material is properly classed, described, packaged, marked, labeled, and in condition for shipment as required or authorized.” As owners, operators, employers and employees of your facility there are certain responsibilities that have to be maintained in order to ship the hazardous ma- terials discussed.
Important Definitions
Federal regulations require hazardous material training for every “Hazardous Materials Employee.” The DOT requires every “Hazardous Materials Em- ployer” to provide all the necessary information to hazardous material employees so they can perform their individual job functions in a safe and knowl- edgeable manner. (Definitions of these roles are included in the Hazardous Materials Guide.)
A Hazardous Materials Employer must be trained to certify Hazardous Materials Employees or provide certification training to those employees responsible for preparing hazardous materials for shipping. The required areas of training include: General Awareness/Familiarization: General aware- ness and familiarization training is intended to raise the HazMat employees’ awareness of the regulation and the purpose and meaning of the hazard commu- nication requirements. All HazMat employees must have this training to make sure hazmat employees can identify and recognize that the airbag/modules, seat belt pre-tensioners and Li-ion batteries are hazardous. Function-Specific Training: Function specific training is intended to teach the necessary knowledge, skills and abilities for an individual’s job function, and specifically to train them to prepare materials for shipment. Safety Training: This training provides informa- tion concerning the hazards posed by materials in the workplace and personal protection measures. The training may include basic emergency response procedures but is not intended to satisfy the require- ments of OSHA (29 CFR 1910.120). Security Training: Each HazMat employee must re- ceive security awareness training of security risks as- sociated with hazardous materials transportation and methods designed to enhance transportation security for facilities with large quantities being shipped. HazMat employees must receive this training and certification at least once every three years. DOT reg-
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ulations require that HazMat Employers train, test, and maintain test records for all HazMat Employees in these areas. A new HazMat employ- ee who changes job functions may perform those functions prior to completion of train-
ing, provided the employee performs those functions under the direct supervision of a properly trained and knowledgeable HazMat employee; and the training is completed within 90 days after employment or job function. The training documentation must include the HazMat Employees name, completion date and location of training, name and address of the trainer, and a copy of the test and certificate.
Preparing Hazardous Material for Shipping General requirements for shipping airbags mod-
ules or seat belt pre-tensioners are that they must be prepared for shipment in a very specific manner. They must be shipped in what is referred to as “per- formance UN packaging.” Also there are terms and numbers that must be printed on the shipping pa- pers, shipping boxes, or both. HazMat shipping pa- pers provide information on several things including; shipper/receiver name and address, HazMat descrip- tion, DOT proper shipping name, quantity, emer- gency response information and certification and signature. If you ship or deliver HazMat in your own vehicle, such your own pick-up truck or delivery van, then you must comply 100 percent with these regula- tions. Under this scenario no placards are required on the vehicle.
HazMat Description
Hazardous Class or Division refers to the category of hazard assigned to a hazardous material under the definitional criteria of part 173 of the CFR. Air bag modules, air bag inflators and seatbelt pre-tensioners can be classified as Class 9 or 2.2 Hazardous Materials depending on the ignitor material. Lithium-ion bat- teries can be classified as Class 9.
Pyrotechnic air bag modules, air bag inflators, and seat-belt pre-tensioners are classified as CLASS 9 MIS- CELLANEOUS HAZARDOUS MATERIALS. Compressed gas air bag modules, air bag inflators, and seat-belt pre-tensioners are classified as DIVI- SION 2.2 NON-FLAMMABLE COMPRESSED GAS HAZARDOUS MATERIALS.
Lithium-ion batteries are classified as CLASS 9 MIS- CELLANEOUS HAZARDOUS MATERIALS. UN Number: UN stands for United Nations. The UN number contains 4 digits and refers to packaging con- forming to standards in the United Nation Recom-
July-August 2018 • AUTOMOTIVE RECYCLING
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