Tech Module 01 Student Text

Student Text IAFF Training for Hazardous Materials: Technician©
Module 1:
Regulations
Module 1: Regulations 1-1

IAFF Training for Hazardous Materials: Technician© Student Text
1-2 Module 1: Regulations

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:
NFPA OSHA
Objectives Standards Standards
• State the purpose of hazardous materials regulations. NFPA 472 29CFR 1910.120
1-1.1 & 1-1.2 (q) (6) (iii)
• Define a hazardous material. NFPA 472 29CFR 1910.120
1-2 & 2-2.1.1 (q) (6) (iii) (B)
• List and describe nine hazard classes and the respective hazard NFPA 472 29CFR 1910.120
divisions. 2-2.1.2 % 2-2.1.3 (q) (6) (iii) (B)
• Distinguish among packing groups I, II, and III. NFPA 472 29CFR 1910.120
1-2 (q) (6) (iii) (B)
• List four hazard zones. NFPA 472 29CFR 1910.120
3-4.1.1 & 3-4.1.2 (q) (6) (iii) (F)
• Identify a hazardous material by its hazard class and division, packing NFPA 472 29CFR 1910.120
group, and hazard zone, using analytical data. 3-2.1.2 (q) (6) (iii) (B)
• Label packages using primary and subsidiary labels. (E) (F)
• Differentiate between technical and generic shipping names. NFPA 472 29CFR 1910.120
3-2.2 (q) (6) (iii) (B)
• Evaluate hazardous material shipping papers. NFPA 472 29CFR 1910.120
3-2.2 (q) (6) (iii) (B)
• List special provisions applicable to hazardous material shipments. NFPA 472 29CFR 1910.120
4-2 thru 4-6.3.10 (q) (6) (iii) (B)
• Describe packaging requirements found in hazardous material regula- NFPA 472 29CFR 1910.120
tions. 1-2 (q) (6) (iii) (B)
• Identify symbols used in the Hazardous Materials Table. NFPA 472 29CFR 1910.120
4-3.3 (a) 2 (q) (6) (iii) (B)
• Evaluate primary and subsidiary hazards using shipping names, NFPA 472 29CFR 1910.120
shipping papers, and the precedence table. 4-3.3 (a) 2 (q) (6) (iii) (B)
• Correctly identify DOT hazard labels for hazmat shipments. NFPA 472 29CFR 1910.120
• Use primary and subsidiary hazard labels. 2-2.1.7 thru (q) (6) (iii) (B)
• List the five components of DOT marking requirements. 2-2.19, 3-2.1.3.2,
• Interpret a packaging label. 4-2.1.2.1
• Define and distinguish between labels and markings. (applies to all of
• Locate the segregation requirements for three pairs of hazard classes on these)
the segregation table.
• Describe training requirements and employees covered by any of the fol- NFPA 472
lowing OSHA standards 1910.1200, 1910.120, 1910.134 - 138, 4-1.1
1910.1030, 1910.146.
• List the key elements of 1910.120. 29CFR 1910.120
• List the 5 levels of training described in paragraph (Q) of 29 CFR (q)
1910.120. 29CFR 1910.120
(q)

Instructor Preparation
Instructors should have a basic knowledge of OSHA, EPA, and DOT regulations that cover
hazardous materials and hazardous waste. Instructors should also be familiar with the use,
transportation, and storage of those materials, and the common identification methods used in
industry as well as emergency response.
Select three to five pages from the Hazardous Materials Table (49 CFR 172.101) and make
copies for the students. This table is reproduced on page 19. Plan on giving the Prerequisite
Quiz at the beginning of this module. If any students fail to answer at least half the questions
correctly, they should be directed to read Training for Hazardous Materials Response: Your
Rights 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 Guidebook
Title 49 CFR 171 - 178 (optional)
Title 29 CFR 1910 series (optional)
DOT placards and labels for all classes and divisions
Several examples of HMIS and NFPA labels (completed)
Hazardous Waste Label
Non bulk container for any hazardous material (with label and markings) and accompanying
shipping papers
Hazardous materials (Examples of common household and commercial products that can be
found 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 mantels
NIOSH Pocket Guide to Chemical Hazards
Supplies for Application Exercise (at end of module before appendices)
Transparencies and overhead transparency projector
VCR and Videotape: Colorado Springs Uranium Ore Spill
Approximate Length
This module requires five to seven hours to complete.

Module 1
Prerequisite Quiz
1. Which of the following statements best describes the standards set by the Occupational
Safety and Health Act?
A. OSHA standards apply primarily to emergency responders
B. OSHA standards apply primarily to hazardous waste sites
C. OSHA standards apply primarily to local, state, and federal workers
D. 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 response
B. EPA regulations apply primarily to hazardous wastes
C. EPA regulations apply primarily to local, state, and federal work sites
D. 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 emergency
response is:
A. 29 CFR 1910.120
B. 29 CFR 1400z
C. 49 CFR Subchapter C
D. 49 CFR 172.101
5. OSHA’s Hazard Communication Standard is:

A. An employer right-to-know law
B. An emergency worker right-to-know law
C. A community right-to-know law
D. 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 America
B. Only within the United States
C. Only within the country of origin
D. Internationally
8. Hazardous materials that must always be placarded, regardless of quantity, are:

A. Table 1 materials
B. Table 2 materials
C. Other Regulated Materials (ORMs)
D. Flammable chemicals
9. Title 49 in the Code of Federal Regulations includes all:

A. EPA Regulations
B. OSHA Regulations
C. DOT Regulations
D. None of the above
10. The Superfund Amendment and Reauthorization Act is administered by:

A. EPA
B. OSHA
C. DOT
D. DOE

Introduction
Questions
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 known

as what standard?
Governing Agencies
In the U.S. there are several agencies that are involved in
regulating chemicals and hazardous wastes. The key
federal agencies are the Department of Transportation
(DOT), which regulates hazardous materials in transit; the
Occupational Safety and Health Administration (OSHA),
which regulates hazardous materials in the workplace; and
the Environmental Protection Agency (EPA), which covers
hazardous waste. Some state and local jurisdictions have
additional regulatory agencies. It is your responsibility to
know your state and local regulations.
These federal agencies communicate their regulations in the

Code of Federal Regulations (CFR). The CFR is a single
or multiple volume set of regulations which is published
annually. Each CFR is organized by a numbering system.
The title of a CFR identifies the agency that wrote the
regulations.

Federal Department Title Number
Department of Transportation 49
Environmental Protection Agency 40
Department of Labor (OSHA) 29
Additionally, the federal government prints the Federal

Register every business day. The Federal Register contains
changes to existing regulations, meeting announcements,
notice of proposed regulations, and the final version of
regulations prior to publication in their respective CFR.
State Regulatory Agencies
The DOT and EPA turn over the regulation of hazardous

materials and wastes to the state regulatory agency only if
the state program meets or exceeds EPA requirements.
Research your state requirements to be sure your actions
reflect these laws.

CFR Structure
The CFR is organized using a numerical system. Each
volume is subdivided using the following hierarchy:
Title Titles are written in numbers (usually

with two digits) in front of the
acronym CFR. [example, 40 CFR]
Chapter Chapter numbers are written in

roman numerals following the word
Chapter after the acronym CFR.
[example, 40 CFR Chapter I]
Part Parts are written in numbers. Part

numbers are assigned numerically
beginning with 1 and continuing
until the regulation is finished (as
high as 1499). [example, 261]
Subpart Subparts are written in capital letters

A through Z and continuing AA
through ZZ. [example, C]
Section Sections are written as numbers

immediately following the decimal
point. Section numbers begin with
the number 1 and continue numeri-
cally until the part is finished.
[example, .7]
Paragraph Paragraphs are written using small

letters beginning with a. Paragraph
designations are placed inside paren-
theses. [example, (a)]
Subparagraphs Subparagraphs are written as small

case roman numbers. Subparagraph
numbers are also placed inside
parentheses and will always follow a
paragraph number.

As indicated earlier, each title number is assigned based on

the department that writes the regulation. Every title is
subdivided into chapters, parts, sections, and paragraphs.
For example, 29 CFR 1910.120(q)(3)(iii) breaks down as
follows:
Title CFR Chapter Part Subpart Section (Paragraph) (Paragraph #) (Subparagraph)
29 CFR I 1910 . 120 (q) (3) (iii)
Each of the three federal agencies discussed in this module

requires some type of emergency response/hazardous
materials contingency plan. These plans can serve as a
basis for pre-incident plans for fixed facilities as well as
some transportation routes. The basic recognition and
identification clues, coupled with facility plans, give you a
tremendous amount of valuable information.

Department of
Transportation
Questions
Refer to the Straight Bill of Lading on the following page to

answer 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 the

transportation of hazardous materials, including hazardous
wastes. The purpose of the hazardous materials regulations
is to identify materials that are dangerous during transporta-
tion and to communicate the dangers and hazards associ-
ated with such materials. In the Hazardous Materials
Transportation Uniform Safety Act (HMTUSA) of 1990,
the DOT mandated that hazardous materials employers
must provide training for all hazardous materials employ-
ees. A hazardous materials employer is defined in 49
CFR 171.8 as
“a person who uses one or more of its employees in
connection with: transporting hazardous materials in
commerce; 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, or
packagings as qualified for use in the transportation
of 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 transportation
safety.”
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 Programs

Administration issued a final rule called HM-126F, Training
for Safe Transportation of Hazardous Materials, thus
amending the Hazardous Materials Transportation Uniform
Safety Act of 1990. This final rule amended the hazardous
materials regulations in order to enhance the training
requirements for persons involved in the transportation of
hazardous materials. Its purpose is to ensure that each
hazardous materials employer trains employees on the safe
loading, unloading, handling, storing, and transporting of
hazardous materials and on emergency preparedness in
response to accidents or incidents involving hazardous
materials. Specifics concerning DOT training requirements
applicable 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 and
bring the United States into compliance with international
hazardous materials shipping regulations. UN Guidelines
require all shipments to be:
• Packaged in United Nations (UN)-specified containers
• Classified, named, marked, placarded, and labeled in

accordance with the Hazardous Materials Table in 49
CFR 172.101

The major purpose of POPS is to identify materials that

may be hazardous during transportation and to communi-
cate the hazards of such materials adequately. The DOT
endorsed POPS for several reasons, including:
• To transport hazardous materials in accordance with UN

guidelines so that a container can be shipped all over the
world with the same markings
• To simplify the hazardous materials transportation regu-

lations
• To reduce the quantity of DOT regulations concerning

hazardous 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 international
hazardous materials transportation regulations occur
smoothly, the DOT has spread compliance dates for POPS
over 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 comply
with POPS.
October 1, 1993 All hazardous materials communication and shipping papers

must comply with POPS.
PIH shipments must be transported in accordance with
POPS.
Shippers must use the Segregation and Separation Table in
49 CFR 177.848.
October 1, 1994 All new packagings must be manufactured in accordance with

POPS.
Shippers can still use “old” packagings.
Infectious substances must be described on shipping papers
and packaged in accordance with POPS.
October 1, 1996 New Generic Shipping Names in HM-215A

Hazardous Materials Table.
Shippers MUST use POPS packagings.
October 1, 2001 HM-181 placards must be displayed for domestic shipments.

Definition of a
Hazardous Material
A hazardous material is defined by the DOT
“to be capable of posing an unreasonable risk to
health, safety, and property when transported.”
Materials designated “hazardous” by the DOT can be found

in the Hazardous Materials Table, 49 CFR 172.101.
Several common chemicals are included in the sample table
on page19. Materials are listed in alphabetical order
according to their proper shipping names (Column 2).
Materials not listed in the Hazardous Material Table may
still 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 Hazardous

Materials Table, yet its flash point is less than 60°C and its
initial boiling point is less than 35°C. Therefore, paint
thinner meets the DOT definition of a flammable liquid
material 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 four
ways to communicate such hazards. These include:
Labels Every hazardous material is required to have

a label(s). The label usually corresponds to
a hazard class and are listed in the Hazard-
ous Materials Table Column 6.
Markings A hazardous material package is required to

be marked with its proper shipping name
and identification number, as well as any
applicable technical names. Additional
marking requirements can be found in 49
CFR 172.301.
Placards Placards are large versions of labels, placed
on transport vehicles and bulk containers.

Shipping Papers
Shipping papers are intended to accurately
describe the hazardous material being
shipped, including its possible hazards.
Shipping papers also identify all parties
associated with the material.
Hazardous Materials
Regulations
Hazardous material regulations are found in Title 49 of the
Code of Federal Regulations. Title 49 is written by the
U.S. Department of Transportation and only applies to
commercial transport.
Title 49 includes all U.S. DOT regulations, not just hazard-

ous material regulations. Hazardous material regulations
are found specifically in Subchapter C, Part 171 through
178. DOT Title 49 CFR can be a tremendous aid to re-
sponders. In addition to the information which was just
covered for highway transportation, 49 CFR also covers
transportation by air, rail, and water. Information such as
tank construction material, working pressures, and types of
relief and control devices can be researched in this CFR.
To identify titles, parts, and sections, use the following
guidelines.
49 CFR 172.101
(Title) (Part) (Section)
The hazardous material table is found in Title 49 of the Code

of Federal Regulations (CFR), Part 172, Section 101.

49 CFR 172.101 Hazardous Materials Table
S Hazardous Materials Hazard Class UN/NA Packing Groups Labels Special Packaging Quantity
y Shipping Names or Division ID Numbers Required Provisions Authorization Limitations
Student Text
m (unless 173.***
b excepted)
o
l
s 8 9
1 2 3 4 5 6 7 Excep- Non- Bulk P.A Cargo.

tions Bulk and Aircraft
R.C.
Acetone 3 UN 1090 II Flammable T8 150 202 242 5L 60 L

Liquid
Corrosive Liquid, N.O.S. 8 UN 1760 I Corrosive A7,B10,

242 None 201 243 .5 L 2.5 L
II B2,T14 154 202 242 1L 30 L
III T7 154 203 241 5L 60 L
Methylhydrazine 6.1 UN 1244 I Poison, 1,B9,B14,B3

Flammable 0,B72,
Liquid, B77,N34,
Corrosive T38,T43,
T44 None 226 244 Forbid Forbid
+ Nitric Acid, Red Fuming 8 UN 2032 I Corrosive, 2,B9,B32, None 227 244 Forbid Forbid
Oxidizer, B74,T38,
Poison T43,T45
Sulfuric Acid 8 UN 1830 II Corrosive A3,A7,B3, 154 202 242 Forbid 30 L

IAFF Training for Hazardous Materials: Technician©
with more than 51 % acid B83,B84,N34,

T9 T27
1-19
Note: Column 10, which provides limitations on shipment by water is not included in this table.
The hazardous material table contains information neces-

sary to ship specific hazardous materials. The table is the
key to all of the DOT hazardous material regulations.
Column 1 - Symbols.
The following symbols may appear in column #1 of the
hazardous materials table: A, W, D, I, and +.
The letter “A” in column 1 indicates restrictions apply

during transportation by aircraft.
The letter “W” in column 1 indicates restrictions apply

during transportation by vessel.
The letter “D” in column 1 indicates that ONLY domestic

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

tional transportation is permitted.
The “+” fixes the proper shipping name, hazard class and
packing group for that entry without regard to whether the
material meets the definition of that class or packing group
or meets any other hazard class definition.
Symbols Hazardous Materials Shipping Names
D Accumulators, pressurized pneumatic

or 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 the
name/description. Only the non-italicized information
should be included as the shipping name/description. In
addition, proper shipping names may be used in either
singular or plural, capital or lower case letters. Punctuation
marks are not a part of the shipping name/description.
Column 3 - Hazard Class or Division.

Column 3 contains numerical information concerning the
hazard class/division applicable to the hazardous material.
The word “forbidden” may appear in column 3. Never ship
a material listed as Forbidden. NOTE: Any reference to a
Class 3 material may be modified to read combustible
liquid if the material has a flash point above 100oF and
below 200oF and the material does not meet the definition
of any other hazard class.
Column 4 - UN or NA Identification Numbers.

Column 4 lists identification numbers assigned to each
shipping name. Identification (ID) numbers are 4-digit
numbers beginning with the letters UN (United Nations) or
NA (North America). ID numbers beginning with UN may
be transported internationally as well as domestically.
Identification numbers beginning with NA may not be
transported internationally except to and from Canada. The
ID number is a 4-digit number used during emergency
response. With the ID numbers, you can use the North
American Emergency Response Guidebook to locate
information for spill control and containment.
Hazardous Materials UN/NA ID Numbers Packing Groups

Shipping 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 hazardous

materials. Three packing groups are authorized by the U.S.
DOT as:
I Great danger
II Moderate danger
III Minor danger
However, hazardous materials in class 2, 7, and ORM-D
will not have a packing group. Packing groups must always
be communicated using Roman Numerals.
Column 6 - Required Labels.

Column 6 specifies required hazard warning labels. The
first label shown for each entry is the primary hazard label.
Other labels indicated are subsidiary hazard labels and must
not carry the number in the bottom corner.
Hazardous Materials Packing Groups Labels Required

Shipping Names 2 5 unless excepted 6
Acetone II Flammable Liquid
Corrosive Liquid, N.O.S. I Corrosive

II
III
Methylhydrazine I Poison, Flammable Liquid,

Corrosive
Nitric Acid, Red Fuming I Corrosive, Oxidizer, Poison
Sulfuric Acid II Corrosive
Column 7 - Special Provisions.

Column 7 specifies special provisions which are described
below. Special provisions are listed and defined in 49 CFR
172.102. The special provision can consist of both a letter
and a number. The letter part of the provision identifies the
applicable mode of transportation. The number indicates
the position in the list. Use the following key to determine
applicability of the special provisions during shipment.

• A code consisting only of numbers applies to all modes

of 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 of
non-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 less
than 119 gallons or a solid package with a net mass of
less 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 not

apply to the chosen mode of transport, it can be disagreed.
Only investigate applicable special provisions. See 49 CFR
172.102 for the identification of the special provisions.
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,T45

Red Fuming
Sulfuric Acid A3,A7,B3,B83,N34,T9 T27
Column 8 - Packaging Authorizations

Column 8 is designed as a reference and is divided into
three categories: exceptions (8A), non-bulk packaging
(8B), and bulk packaging (8C). Although packaging
requirements are found in 49 CFR part 173, Column 8
communicates the section number of part 173, where
specific packaging requirements are listed.
For example:
Acetone (in a non-bulk package - Column 8B) references
section 202. Refer to part 173, section 202 (49 CFR
173.202) to locate specific packaging requirements for
acetone.

“None”, listed in column 8A, denotes that there are no

exceptions. “None” listed in either column 8B or 8C,
denotes that the U.S. DOT has not authorized material to be
packaged in this manner.
Hazardous Materials Packaging Authorizations 8
Shipping Names (173.***)
2
Exceptions Non-Bulk Bulk
8A 8B 8C
Acetone 150 202 242
Methylhydrazine None 226 244
Nitric Acid, None 227 244

Red Fuming
Sulfuric Acid 154 202 242
49 CFR 173 also states that:

“Each package must be constructed and maintained so that
there will be no identifiable release of hazardous materials
to the environment; the effectiveness of the package will not
be substantially reduced; and there will be no mixture of
gases or vapors in the package which could, through any
credible spontaneous increases of heat or pressure, signifi-
cantly reduce the effectiveness of the packaging.”
Consequently, if there is any possibility that the container

could rupture and leak, it should either be overpacked
before shipping, or should not be shipped at all.
Column 9 - Quantity Limitations

Columns 9A and 9B specify the maximum quantity of
hazardous material that may be transported in any one
package. Column 9A refers to transportation by passenger
aircraft or rail car, while Column 9B refers to cargo aircraft
only. “Forbidden” means material may not be transported
by that particular mode. Quantity limitations are net
physical material, unless otherwise specified. All quantities
are listed in metric units of measure.
L = liter (approximately 1 quart)

kg = kilogram (approximately 2 pounds)

Hazardous Materials Quantity Limitations

Shipping Names 2 9
Acetone 5L 60L
Nitric Acid, Forbidden Forbidden

Red Fuming
Methylhydrazine Forbidden Forbidden
Sulfuric Acid Forbidden 30L
Column 10 - Stowage Requirements

Column 10 specifies stowage requirements aboard water
bearing vessels. For more information refer to 49 CFR
172.101 [(k)].
Activity
Hazard Classes
The hazard class system is illustrated on the next page and
lists hazard classes from the most dangerous to the least
dangerous. There are nine hazard classes. When a hazard
class is shown on labels, markings, placards, and shipping
papers, it is indicated by numbers 1 through 9. Some
hazard classes have subclasses, which are called divisions.
A division is indicated by a number to the right of the
decimal. 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). The
number to the left of the decimal is the hazard class number
(in this case, “1” indicates an explosive) and the number to
the right of the decimal is the division number. In this case,
“.6” indicates an extremely insensitive explosive.

HAZARD CLASSES
Hazard Class Hazard Class Hazard Class/ Hazard Division

Description Division Description
1 Explosives 1.1 Mass Explosion Hazard

1.2 Projection Hazard
1.3 Fire Hazard
1.4 No Blast Hazard
1.5 Insensitive Explosive
1.6 Extremely Insensitive Explosive
2 Compressed Gases 2.1 Flammable

2.2 Non-Flammable and Non-Poisonous
2.3 Poisonous
3 Flammable Liquid NO DIVISIONS
4 Flammable Solid 4.1 Flammable Solids

4.2 Spontaneously Combustible
4.3 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
In addition to hazard class and division, a packing group and hazard zone system is used to

further define hazardous materials. There are three packing

groups. They are:
PG I Great Danger
PG II Moderate Danger
PG III Minor Danger
Packing groups determine several key issues in the ship-

ment of hazardous materials. For instance, packing groups
have an impact on the:
• Type of packaging
• Markings
• Quantity restrictions
• Mode of transportation
Every hazardous material has a packing group, except Class

2 (Gases) and Class 7 (Radioactive) materials.
Materials that are poison-by-inhalation (PIH) have a hazard

zone. There are four hazard zones: A, B, C, and D. Those
materials in class/division 2.3 or 6.1 may be PIH materials.

Class 1 Explosives
An explosive is any substance designed to function by

explosion (i.e. an extremely rapid release of gas and heat)
or act like an explosive because of an internal chemical
reaction. 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 have

a mass explosion hazard. A mass explosion
is one that affects almost the entire load
instantaneously. Examples of Division 1.1
explosives include black powder, dynamite,
and TNT.

a projection hazard but not a mass explosion
hazard. Examples of Division 1.2 explosives
include aerial flares, detonating cord, and
power device cartridges.

a fire hazard and either a minor blast hazard
or a minor projection hazard, or both, but not
mass explosion hazard. Examples of Divi-
sion 1.3 explosives include liquid-fueled
rocket motors and propellant explosives.
Division 1.4 Division 1.4 consists of explosive devices

that present a minor explosion hazard. No
device in the division may contain more than
25 g (0.9 oz.) of a detonating material. The
explosive effects are largely confined to the
package and no projection of fragments of
appreciable size or range is expected. An
external fire must not cause virtually instan-
taneous explosion of almost the entire
contents of the package. Examples of
Division 1.4 explosives include line-throw-
ing rockets, practice ammunition, and signal
cartridges.
Division 1.5 Division 1.5 consists of very insensitive

explosives. This division is comprised of
substances that have a mass explosion
hazard but are so insensitive that there is

very little probability of initiation or of
transition from burning to detonation under
normal conditions of transport. Examples of
division 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 of
articles that contain only extremely insensi-
tive detonating substances and that demon-
strate a negligible probability of accidental
initiation or propagation.
Class 2 Gases
The materials included in Class 2 are compressed gases.

The gases are divided into three divisions. Notice that the
basic shipping description for a material in Class 2 does not
include a packing group!
Division 2.1 Flammable gases are defined as “a material

which is a gas at 68°F or less and 14.7 psi
and which is ignitable at 14.7 psi when in a
mixture of 13% or less by volume with air,
or has a flammable range at 14.7 psi with
air of at least 12%, regardless of the lower
flammable limit.” An example of a basic
shipping description for a flammable gas:
Butylene, 2.1, UN 1012.
Division 2.2 Non-flammable, non-poisonous compressed

gases are described as “a material or mix-
ture that has an absolute pressure of 41 psi
at 68°F and does not meet the definition of
Division 2.1 or 2.3.” An example of the
basic 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 are

known to be toxic to humans and, therefore,
pose a hazard to health during transporta-
tion. Because all Division 2.3 materials are
poisonous-by-inhalation, they will be as-
signed one of four hazard zones (A,B,C,D).
The hazard zone indicates the intensity of
the hazard. In general, Zone A is the “most
poisonous” and Zone D the “least poison-
ous.” Zone definitions are based on an
established toxicity values (LC50) deter-
mined from animal testing. For more
information on gases which are poison-by-
inhalation, refer to 49 CFR 173.133. An
example of a compressed gas that is poison-
ous-by-inhalation is hydrogen sulfide gas.
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
Class 3 Flammable and

Combustible Liquids
Flammable Liquid
A flammable liquid is defined as “a liquid having a flash

point of not more than 60.5°C (141°F).” Examples of
Class 3 materials include acetone and isopropanol. Class 3
materials are divided into packing groups based on their
degree of danger. The following chart distinguishes among
Class 3 packing groups.

Initial Boiling Point (°C)
PG Flash Point (Closed-Cup) Initial Boiling Point
I < 35 C
II < 23 C > 35 C
III > 23 C < 60.5 C > 35 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 any
other hazard class. A flammable liquid may be reclassified
as a combustible liquid if the flash point is greater than
100°F/less than 141°F and the liquid does not meet the
definition of any other hazard class. Hazardous materials
regulations allow the shipper latitude over shipment of
materials 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 when
wet). 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 a
liquid is pyrophoric, it will be classed Division 4.2. The
property of spontaneous combustion is more important
than the form of the material.
Division 4.1 Flammable solids include the following

materials:
• 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.

Packing groups for Division 4.1 materials are based on the

materials burning rate and zone of reaction. The following
table shows the conditions of each packing group.
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
Division 4.2 Spontaneously combustible materials,

including the pyrophorics and self-heating
materials, are included in Division 4.2.
Specific examples are potassium sulfide and
aluminum borohydride.
PG Pyrophoric Liquids Self-Heating Positive

Test 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 ignite

spontaneously or give off flammable or toxic
gas when in contact with water. Specific
examples are aluminum carbide,
ethyldichlorosilane, and metal alloys.
Packing Group Evolution of Gases (Flammable gas

evolution 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
Class 5 Oxidizers
Oxidizers release oxygen, which enhances the combustion

of other materials. Class 5 materials are chemically active
and are often involved in industrial reactions. For example,
when an oxidizer is mixed with an organic, the result could
be an explosion. Consequently, basic chemistry mandates
isolation or segregation of Class 5 materials.
Division 5.1 An oxidizer is a material that may, by

yielding oxygen, cause or enhance the
combustion of organic materials, such as
wood or solvents. Examples are nitrates
and aluminum dichromates. Packing
groups are determined by mean burn times
of the unknown, then compared to burn
time of either an ammonium persulfate
mixture or a potassium perbromate mix-
ture.

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)2S2O8
(mbt = mean burn time)
Division 5.2 Organic peroxides are identified by hazard

class/division 5.2. Specific packaging
requirements can be found in 49 CFR
173.225. Two significant hazards are
associated 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 necessary
for the organic peroxides. Benzoyl perox-
ide is an example of a division 5.2 mate-
rial.
Activity

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 the
etiological (disease causing materials) agents into hazard
class 6. Packing Groups as well as hazard zones may be
assigned to hazard class 6 materials. Chlorinated solvents,
such as carbon tetrachloride and methylene chloride, are
classified as Class 6.1 materials.
Division 6.1 Poisons are materials (other than gases)

known to be toxic during transportation or
have a toxic effect on test animals. Some
division 6.1 poisons are poisonous by
inhalation. Examples of 6.1 materials
include: calcium cyanide, nicotine, and
methyl isocyanate. The table below associ-
ates hazard zone and Packing Group to
analytical data obtained for the poisons.
Information can be found in RTECS (The
Registry for Toxic Effects of Chemical
Substances). The RTECS reference can be
obtained through the local government
bookstore.
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 liquids

based on inhalation of vapors must be in accordance with
the following table:
Packing Hazard Zone Vapor Concentration and Toxicity

Group
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 I
are not met.
III V > .2 LC50; LC50 < 5000 mL/m3;

and the criteria for Packing Groups I
and II are not met.
.
Division 6.2 Substances that contain a viable microor-

ganism or microbial toxin and have the
potential to cause disease in humans or
animals are regulated as hazardous materi-
als, identified in hazard class/division 6.2.
This includes biologically infectious mate-
rials or etiological agents. Examples of
class 6.2 materials include: blood, blood
contaminated equipment, and aflatoxins.

Class 7 Radioactive Material
A radioactive material emits ionizing radiation. Material

with an activity of 0.002 micro curies per gram or more is
subject to regulation. Activity is measured at the package
surface. 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 the
most 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, uranium

235 and thorium compounds.
Class 8 Corrosive Material
A solid or liquid that causes irreversible harm to human

skin (necrosis) over a specified (4 hour) period is regulated
as a corrosive. A liquid causing severe corrosion
(6.25 mm/g at 55 degrees C) on steel or aluminum is also
regulated as a corrosive.
As of December 29, 1994, the US DOT now allows the use

of pH to determine corrosivity. Class 8 materials are
chemically described as either acidic (a low pH) or basic (a
high pH). Corrosives are assigned to packing groups based
on necrosis time.
There are no divisions associated with hazard class 8.

Examples of corrosive materials include: mercury, battery
acid, nitric acid, sulfuric acid and sodium hydroxide.

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
Generic shipping names must accurately describe the

hazardous 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 the
proper shipping name. (i.e. corrosive liquid, acidic, organic,
n.o.s.)
Class 9 Miscellaneous
Hazardous Materials
This hazard class encompasses “everything else.” A mate-

rial which “presents a hazard during transport, but which
is not included in any other hazard class, may be trans-
ported as a class 9 hazardous material.” Any material
regulated as a hazardous substance, hazardous waste, or
marine pollutant must be regulated during transportation
and described by hazard class 9. Listed below are the most
common generic shipping names used to transport hazard
class 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 numbers

are different for liquids and for solids. It is recommended

that shippers use the “Environmentally Hazardous Sub-

stance” shipping name when shipping materials which do
not appear on the hazardous materials table but are
regulated by another federal agency (EPA or OSHA).
Other Regulated Materials
“ORM” hazard classes no longer exist. The exception is

the ORM-D hazard class. Consumer commodities will be
transported as an ORM-D. Materials packaged and distrib-
uted in a form intended for retail sale or for consumption
by individuals for the purpose of personal care/household
use are consumer commodities. Note that consumer com-
modities are not exempt from the hazardous material
regulations. Instead, handle the consumer commodity as a
specific hazardous material. Packaging requirements,
marking requirements, and labeling requirements will be
subject to US DOT regulation. Molten sulfur is an example
of an ORM-D material.
Activity

Shipping Papers
Shipping papers communicate information regarding a
material’s hazard and must accompany every hazardous
materials shipment transported by train, plane, vessel or
truck.
Shipping papers available at an incident scene aid your

emergency response. The U.S. DOT regulates transporta-
tion by several modes of transportation, including air,
water, rail, and highway. Shipping papers are specific to
the mode of transportation.
Transportation Shipping Paper Responsible Person

Mode Title
Highway Bill of Lading or Uniform Driver

Hazardous Waste Manifest
Rail Waybill Crew
Water Dangerous Cargo Manifest Captain
Air Air Bill with Shipper’s Pilot

Certification for Restricted
Articles
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 Federal
Regulations requires specific information on shipping
papers, including:
• Consignor (name, address)
• Consignee (name, address)
• Shippers Certification
• Basic Shipping Description
• Quantity Shipped




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.
Required Hazardous Materials

Shipping Paper Table Column
Information
Proper Shipping Name 2
Hazard Class 3
Identification Number 4
Packing Group 5
Shipping papers communicate information based on the

proper shipping name assigned to the hazardous material.
There are two types of shipping names associated with
hazardous materials. These shipping names are applicable
for transportation of hazardous wastes, hazardous materials,
or hazardous substances.
Technical Shipping Names are used when transporting a

single hazardous material. The word mixture or solution is
added 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 a

mixture of two or more hazardous materials. Identify the
generic 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 appear

before the proper shipping name (PSN).

First, the word “waste” will appear before the PSN (if it is
not a part of the shipping name) only if the hazardous
material being transported is an EPA designated hazardous
waste.
Second, the letters “RQ” may appear before the PSN. The
letters RQ will appear if the quantity transported, in a
single container, exceeds the designated reportable quantity.
Refer to Title 49 of the Code of Federal Regulations

172.101 Appendix A. The table below lists examples of
basic shipping descriptions. Each example communicates
information concerning a hazardous waste. When shipping
a hazardous material, use the same information in the same
order. The only difference is the omission of the word
waste.
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
To be current, the shipping papers must:
• Use numerical divisions and hazard classes
• Communicate information concerning packing groups

in Roman Numerals
Classification of Materials
Containing Multiple Hazards
Hazardous materials can contain multiple hazards. When

multiple hazards are present, determine the hazard prece-
dence by use of the following series of tables.

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
The Precedence Chart should only be used if items 1

through 7 are not applicable.
Directions for use of the Precedence Hazard Table on the

following page:
First, determine the hazard class and packing group for
each constituent material in the mixture. Utilize the table
like a multiplication chart, plug information from one
constituent along the top and information from the second
constituent along the left. The point of intersection deter-
mines the primary hazard. The subsidiary hazard is NOT
represented on the chart.

Precedence Table
1
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 properly
marked 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 Table
are required during shipment domestically or
internationally. These labels will help responders
identify materials involved in an incident.
Labels
A label describes the hazards of the material within a

container. Examples of labels include the hazard label and
the inhalation hazard label (if applicable).
When the hazardous material presents multiple hazards,

multiple labels must be used. The first label listed in
column 6 is the primary hazard label; all others are
subsidiary hazard labels. Warning labels should be
placed within six inches of the product or waste label and
no more than six inches from each other. Also, the primary
label should be above and to the left of the subsidiary label.
Remember the subsidiary label will not have a number in
the bottom corner indicating hazard class.
Placement of Labels
Labels should be located near the proper shipping name

and on the same surface. Labels should not be placed on
the bottom of a container and must be visible even while
riding in a vehicle. The label may not be obscured by
markings or other attachments and labels must be indicative
of the hazard the material presents. It is illegal to place
labels on containers which present no hazard.
Marking Requirements
A marking is information that is placed onto the container

of a hazardous material before shipping. Markings do not
describe the hazard associated with the material, instead a
marking describes the package and the material inside the

package. Markings can also indicate package orientation.

Preprinted forms containing marking information can be
applied to the container and/or markings can be indelibly
marked (engraved, molded, or printed) onto the container.
Marking requirements are divided into five components.
Proper shipping names Include identification numbers
Technical names Only for material shipped under

a generic shipping name
Special hazard warnings Package orientation marking

Ex: “Inhalation Hazard”
“Marine Pollutant”
“RQ”
Exemptions There are occasions when the material that is

transported can be placed in containers that
have an exemption. If for some reason a
material is covered by an exemption, then
the container should be marked with DOT-E
followed by the exemption number that has
been assigned by DOT.
Consignee name The consignor is the organization where a

and address shipment begins. Shipments are made to the
consignee.
Inhalation Hazard
Inhalation hazard markings are required for Division 2.3

materials and Division 6.1 materials which are poisonous
by inhalation. The words “Poison-Inhalation Hazard” and
the words “Hazard Zone A”, “Hazard Zone B”, “Hazard
Zone 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 the

shipping description

• Marked on each non bulk package in association with

the proper shipping name and identification number
• Marked on two opposite sides of each bulk package.

Size of markings on bulk packages must conform to
172.302 (b) of this subchapter
Inhalation hazard labels should be within two inches of the

product label and on the top of the container.
This End Up
All non bulk combination packages of hazardous materials

having 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 arrows
pointing up
Note: Although arrows for purposes other than indicating

proper 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 is
known as a combination package. The inner packages may
be containers made of glass, plastic, or even metal. The
inner packages do not have to be U.S.DOT approved
containers. Combination packages are not only marked
with 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 arranged

so that their openings correspond to the label arrow
direction.
• The outside container must be marked with package

orientation labels on two opposite sides.
• These package orientation labels must meet certain

standards, meaning that they cannot be drawn on the
container.
Activity
U.S. DOT Package Marking
As of October 1, 1994, only UN approved packages will be

produced. Package markings must be indelibly entered onto
the package and indicate UN approval. UN package mark-
ings are required for packages containing hazardous materi-
als. The United Nations specification containers use a
standard 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:
U
N

Part 2 (Package Code)
1AH 2
The packaging code consists of numbers and letters. The

first number communicates information concerning the type
of package.
1) Drum
2) Wooden Barrel
3) Jerrican
4) Box
5) Bag
6) Composite Packaging
7) Pressure receptacles
The letter or letters indicate package construction

material(s).
A) Steel
B) Aluminum
C) Natural Wood
D) Plywood
G) Fiberboard
H) Plastic
L) Textile
M) Paper, multiwall
N) Metal (other than steel or aluminum
P) Glass, porcelain or stoneware
The last number identifies the package closure or lid
1. Closed Top
2. Open Top
Part 3
The packing group is also designated within the package

marking. Use the following key to signify packing groups
acceptable 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

Note: “X” containers must meet the most stringent stan-

dards and severe package testing requirements, thus any
packing 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 the

material the package can contain. If the package is de-
signed to contain a Packing Group I material, then the most
stringent performance requirements must be met. For
example, the performance standards for the drop test of an
“X” package require that the container be dropped from a
height of approximately six feet without leaking or denting.
A “Y” package is dropped from a height of approximately
four feet, and a “Z” package is dropped from a height of
about 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 in

accordance with a pre-determined statistical quality control
plan. 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 the
package. In the following example, the container is in-
tended for only a solid and the maximum gross weight
associated with the container is 165 kilograms.
S 165
If a package is designated to contain liquids, two numbers

will appear in box four. The first number communicates the
maximum specific gravity the container can hold. The
second number communicates (in kilopascal) the pressure
the container was tested under.
1.4 160

Every container intended to house a liquid must be perfor-

mance tested. In the above example, the container is
intended to house a liquid, in fact the maximum specific
gravity associated with the liquid is 1.4 gm/cm3. In addi-
tion, the container was tested in the leakproof test under
160 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 two
digits associated with the calendar year in
which the container was made.
Box 6 - The symbol for the country where the

container was manufactured will be listed in
box 6. American manufactured UN contain-
ers will have a USA in box 6.
Box 7 - The last standard part of the UN marking

will be the name of the manufacturer’s name
or registered symbol (U.S. DOT registered).
Part 8
A thickness will be included in the marking only if the

container may be re-used. If a thickness (in mm) does not
appear as the last part of the marking then the container is a
single use container. The container must never be retested
for reuse. If the thickness exceeds 8 mm, then the container
can only be reused after retesting. Send the DOT empty
container to an approved re-conditioner, who will restamp
the container once the performance retest has been com-
pleted.
Example of a UN Code
Package intended for solid material
U 1AH2 Y 145 S 92 USA VL 6mm

N 824

Package intended for a liquid material
U 1AH2 Y 1.4 92 USA VL 6mm
Re-tested package label
10-93 USA VL824 RL
DOT Load Segregation

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

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 manner
that, in the event of leakage from packages under conditions normally incident to transportation, commingling of
hazardous 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 that
shippers may load truckload shipments of such materials together when it is known that the mixture of contents
would 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) or
Division 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 applied
when 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 Safety
and Health
Administration (OSHA)
Questions
1. Is your state covered by OSHA or subject to EPA

standards?
2. How do regulations from these two agencies differ?
The second phase of a hazardous materials life cycle is

receipt of the material into a facility and its subsequent use.
After a DOT hazardous material is received into a facility, it
is no longer regulated by DOT because it is no longer being
transported. Inside the facility, the safe use and marking or
communication 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 of
workers. We will specifically address those workers who
are considered to work in general industry.
Regulated Sites
There are many different types of sites that use or store
hazardous materials. Generators have disposal storage areas
where waste is picked up. These areas may be inside or
outside. Superfund sites are usually larger old dump sites
where containers are being extracted from the ground.
Clean-up sites can be small spills from tank cars or nearby
roadways or can be areas contaminated from industrial
equipment use. Waste from generators may pass through a
transfer and storage facility where containers are moved
from one transportation vehicle to another. Hazardous
materials are also used during production at many industrial
sites. Training is required for involvement in emergency
response to incidents at these industrial sites.

Minimizing Work Place Hazards
To work in a safe and healthy environment, workers must

participate actively in a comprehensive safety program.
One key element of any safety program is the goal to
minimize hazards in the work place. In order to success-
fully minimize hazards, you must first determine which
hazards are present. To minimize risks, employers typically
institute a health and safety program that is cyclic and
includes three phases: recognition, evaluation, and control.
The first step is recognizing or identifying real and potential
hazards and risks. Second, employers evaluate the effect
these hazards have on the work force and compare these
effects against industry standards. Finally, employers are
required to outline methods of hazard control. No employer
is permitted to expose workers to a chemical hazard in
excess of OSHA designated levels.
Compliance
The Occupational Safety and Health Administration, created
within the Department of Labor, outlines requirements
including training for individuals working with hazardous
chemicals. These health and safety requirements are found
in 29 CFR 1910. OSHA also assists in creation of personal
protective equipment standards and helps in regulation of
specific processes, including lockout/tagout, confined space
entry, 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 employees

in the 50 states, the District of Columbia, Puerto Rico, and
all 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 are

not. States not covered by OSHA are subject to EPA health
and safety standards.

Standards Promulgated by OSHA

OSHA is responsible for promulgating legally enforceable
standards. OSHA standards fall into four categories:
• General Industry
• Maritime
• Construction
• Agriculture
Occupational Illness and Injury

Facilities with 11 or more employees must maintain records
of occupational injuries and illnesses as they occur. An
occupational injury is an injury such as a cut, fracture,
sprain or amputation which results from a work-related
accident or from exposure involving a single incident in the
work place. An occupational illness is any abnormal
condition or disorder other than one resulting from an
injury, caused by exposure to environmental factors associ-
ated with employment. Included are acute and chronic
illness 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 and
safety program. Most facilities choose to extend this
program to contractors, subcontractors, visitors, regulatory
agency 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 and

safety of workers. Some of the standards that apply to
industry are:
29 CFR 1910.1200 Hazard Communication
29 CFR 1910.120 Hazwoper
29 CFR 1910.146 Confined Space
29 CFR 1910.1030 Bloodborne Pathogens
29 CFR 1910.147 The Control of Hazardous Energy
29 CFR 1910.133 Eye and Face Protection
29 CFR 1910.134 Respiratory Protection
29 CFR 1910.135 Occupational Head Protection
29 CFR 1910.136 Occupational Foot Protection
29 CFR 1910.138 Occupational Hand Protection

29 CFR 1910.95 Occupational Noise Exposure
Following is an overview of these standards.
Hazard Communication
Standard (29 CFR 1910.1200)
OSHA has written a standard that requires employers to
identify the hazards present in the work place. The hazard
communication standard, written in 1987, outlines methods
for identifying and communicating the presence of hazards.
Also known as the employee Right-to-Know law, the
hazard communication standard applies to all chemicals
that pose hazards to the workers. This standard categorizes
chemicals based on their threat to human health. Hazards
at hazardous waste operations and emergency response
sites can be classed into two categories: safety hazards and
chemical hazards.
Chemical hazards pose either a health hazard or a physical

hazard to the worker. While there are two broad categories
of 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 thermal

extremes. Safety hazards result from conditions in the
work place that might harm workers. Safety hazards
include:
• 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 using

good hazard communication labels. Various types of
hazards are shown on the following pages.

Types of Hazards
Hazards
v v
Safety Chemical
v v
Physical Health

Chemical Hazards
Health
v v v v v v
Carcinogens Sensitizers Irritants Reproductive Corrosives Poisons

Chemical Hazards
Physical
Explosives Flammables Reactives Oxidizers
Pyrophoric Combustibles Water Air

HAZWOPER
(29 CFR 1910.120)
OSHA’s 29 CFR 1910.120 deals with hazardous waste
operations and emergency response. The standard targets
three separate groups of workers including:
• Employees who work at RCRA facilities
• Employees who respond to emergencies
• Employees who work at clean-up sites dealing with

hazardous substances
29 CFR 1910.120 is divided into seventeen paragraphs, A

through q, and includes requirements such as medical
monitoring, health and safety plans, and site characteriza-
tion. Employees who work at RCRA facilities are covered
by paragraph P. Employees who work at clean-up sites are
covered by paragraphs B through O. Fire fighters who
handle emergency response are covered by paragraph Q.
A breakdown of paragraphs B through P is in Appendix B
of this module. Paragraph q is described here.
Paragraph Q — Emergency Response
This paragraph covers employees who are responding to an

emergency response regardless of the location. Elements of
paragraph Q include:
A. Development of an Emergency Response Plan with the

following 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 response

C. Skilled support personnel
D. Specialist employees
E. Training. Five levels of training are outlined. These
five levels follow a hierarchy in terms of training and
responsibility for responding to an emergency. The five
levels (in ascending order of responsibility) are:
1. First Responder Awareness Level: Use senses and
job knowledge to be alert to an emergency and
initiate the ER team.
2. First Responder Operations Level: Recognize an
emergency and take a defensive posture by isolating
the area and containing the release.
3. Hazardous Materials Technician: Recognize the
hazards of the release and take an offensive posture
by stopping the release.
4. Hazardous Materials Specialist: Support the techni-
cian with a more specialized knowledge of the
hazards present.
5. On-site Incident Commander: The most senior
official at the scene. Responsible for making the
decisions and assigning duties.
F. Trainers
G. Refresher training
H. Medical surveillance and consultation
I. Chemical protective clothing
J. 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 OSHA

standards that are in place today to protect the worker from
particular safety, physical and health hazards. To find out
specific information, refer to the Code of Federal Regula-
tions and your local and state regulations.

Other OSHA Standards

1910.146
The Confined Space Standard identifies requirements for
confined space entry as well as practices and procedures to
protect employees from the hazards of permit-required
confined spaces.
1910.1030
The Bloodborne Pathogen Standard covers occupational
exposure to blood or other potentially infectious materials.
This standard focuses on communicable disease such as
HIV and Hepatitis B.
1910.147
The Control of Hazardous Energy, more commonly known
as Lockout/Tagout (LO/TO) Standard establishes minimum
performance requirements for control of energization (start
up) of machines or equipment, or the release of stored
energy that could cause injury. This standard requires
employers to publish a written LO/TO program. Facilities
are required to institute policies and procedures which
protect workers from mechanical hazards during routine
maintenance.
1910.133
In 1910.133, OSHA identifies acceptable eye and face
protection. Eye and face protection are required when a
reasonable probability of injury exists.
1910.134
The primary objective of the Respiratory Protection Stan-
dard is to control occupational disease caused by breathing
contaminated air. Breathing air is contaminated when
harmful dusts, fogs, fumes, mists, gases, sprays, or vapors
exist in the work place.
1910.135
The Occupational Head Protection Standard requires
workers to wear protective helmets when working in areas
where the potential for head injury exists due to falling
objects.

1910.136
The Protective Footwear Standard protects employees
working in areas where harmful foot exposure exists.
Protective footwear must be issued when hazards from
falling and/or rolling objects, objects piercing the sole, or
even electrical hazards are present in the work place.
1910.138
Protective 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 or
lacerations, severe abrasions, punctures, chemical burns,
thermal burns, and/or temperature extremes.
1910.95
The Occupational Noise Protection Standard identifies the
type of protection necessary against a variety of noise
exposures. In addition, the standard requires facilities to
establish a hearing conservation program and communicate
the effects of noise exposure.
Most of these standards are referenced in 29 CFR 1910.120.

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


Environmental
Protection Agency
The third phase of a product’s life cycle is the waste cycle.
After a material has been used in a facility, it may be
reprocessed and redistributed, or disposed of. Either way,
a new set of regulations, enforced by the Environmental
Protection Agency (EPA), take effect.
U.S. EPA regulates the federal system of hazardous waste

management. It establishes and enforces environmental
regulations, including rules for the management of solid
and hazardous wastes. In 1972, the Environmental Protec-
tion Agency was formally incorporated as a part of the
Department of Labor. Unfortunately the EPA had no
enforcement power. In 1976, Congress voted yes on a
landmark decision and the Resource Conservation and
Recovery Act (RCRA) was voted into law. EPA enforces
RCRA. Over the next decade, Congress repeatedly stressed
environmental 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 environmental

regulations with the greatest impact on health and safety
concerns.

The Resource Conservation

and Recovery Act (RCRA)
The Resource Conservation and Recovery Act has been
incorporated into the 40 CFR, specifically part 260 through
270. RCRA is regulated by the Environmental Protection
Agency. The Resource Conservation and Recovery Act,
written in 1976, was the first comprehensive federal effort
to deal with solid and hazardous waste. Subtitle C of the
Act was to form and enforce regulations concerning track-
ing and managing hazardous wastes from the point of
generation to the ultimate disposal—“cradle to grave”
management.
RCRA states that persons managing solid wastes are

charged with the responsibility of identifying those wastes
which meet one or more of the characteristics of hazardous
wastes. Such persons are responsible also for providing
notification to EPA of any waste disposal activity involving
hazardous wastes. Persons who have solid wastes that meet
the 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 of
hazardous waste from the generation point to the ultimate
treatment or disposal site. Generators must also use those
transporters and treatment, storage, or disposal facilities
(TSDF) that are appropriately licensed by the federal and
state governments. Finally, RCRA gave the EPA the power
to enforce the regulations written and adopted in title 40 of
the Code of Federal Regulations.
The following list outlines the regulations listed in the 40

CFR that are applicable to RCRA. It is this portion of the
regulation where definitions and generator requirements are
found.

Subpart A General
Section 261.1 Purpose and scope

Section 261.2 Definition of solid waste
Section 261.3 Definition of hazardous waste
Section 261.4 Exclusions
Section 261.5 Special requirements for hazardous
waste generated by conditionally exempt
small quantity generators
Section 261.6 Requirements for recyclable materials
Section 261.7 Residues of hazardous waste in empty
containers
Section 261.8 PCB wastes regulated under Toxic
Substance Control Act
Subpart B Criteria for Identifying the Characteristics of

Hazardous Waste and for Listing Hazardous
Wastes
Section 261.10 Criteria for identifying the characteristics

of hazardous waste
Section 261.11 Criteria for listing hazardous waste
Subpart C Characteristics of Hazardous Waste
Section 261.20 General

Section 261.21 Characteristic of ignitability
Section 261.22 Characteristic of corrosivity
Section 261.23 Characteristic of reactivity
Section 261.24 Toxicity characteristic
Subpart D Lists of Hazardous Wastes
Section 261.30 General

Section 261.31 Hazardous wastes from non-specific
sources
Section 261.33 Discarded commercial chemical
products, off-specification species,
container residues, and spill residues
thereof
Section 261.35 Deletion of certain hazardous waste
codes following equipment cleaning and
replacement

Definitions
One of the basic purposes for RCRA, as it was written in

1976, was to establish a framework for environmental law
and regulation. RCRA began by defining waste. Defini-
tions then snowballed and as the environmental laws appear
today, the most complex issue has been in keeping the
definitions 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 for
recycling or reclamation and must be classified and conse-
quently regulated as a waste. A material can be declared to
be a solid waste regardless of physical state (a solid, liquid,
or gas).
Lab Sample
Lab samples are not considered waste, but must be labeled

in accordance with DOT regulations.
Characteristics of Hazardous Waste
A waste is declared to be a hazardous waste if it meets the

definition of a solid waste and the definition of a character-
istic waste. A characteristic waste exhibits one of four
hazardous 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 flash
point is less than or equal to 1400F. A flash point less than
1400F indicates the waste is hazardous and should carry a
D001 waste code.

Characteristics of Ignitable Waste (D001)
All solid waste that exhibits the characteristic of ignitability

carries the EPA designated hazardous waste code of D001.
EPA regulation 40 CFR 261.21 describes four types of
ignitable hazardous wastes:
• Liquids having a flash point below 140oF (These waste

streams must be non-aqueous solutions containing less
than twenty-four percent by volume of alcohol.)
• Non-liquids (solids, rather than gases) that may cause

fire through friction, absorption of moisture, or sponta-
neous chemical changes
• Certain ignitable compressed gases
• Oxidizers, as defined in 49 CFR 173.151 (An oxidizer

is a substance, such as a chlorate, permanganate, inor-
ganic peroxide, or nitrate, that readily yields oxygen to
energize 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. Aqueous
solution is not formally defined in the regulations but, as
noted by the EPA, aqueous refers to any solution in which
the primary component is water. Therefore, water must
compose at least fifty percent by weight of an aqueous
solution. A corrosive waste, then, is:
• An aqueous solution with a pH less than or equal to 2 or

greater than or equal to 12.5
• A liquid that corrodes steel faster than .250 inch per
year.
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 stream

as follows:
• Normally unstable and readily undergoes violent

changes 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 the
environment
• Cyanide or sulfide-bearing wastes which can generate
toxic gases, vapors, or fumes when exposed to pH
conditions between 2 and 12.5
Examples of reactive hazardous wastes (D003) include:

potassium cyanide; lithium aluminum hydride; and
trimethylchlorosilane.
Characteristic of Toxic Waste (D004-D043)
EPA waste codes D004 through D043 have been designated

to 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 organic
chemicals exceeding specified concentrations provide
evidence of the characteristic toxicity. Toxicity is evaluated
using the Toxicity Characteristic Leaching Procedure
(TCLP). A solid waste that exhibits the characteristic of
toxicity has the EPA hazardous waste number specified in
Table I which corresponds to the toxic contaminant causing
it to be hazardous.

Waste Code Contaminant Regulatory Level
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
D031 Heptachlor (and its epoxide) 0.008
D032 Hexachlorobenzene 0.13
D033 Hexachloroethane 0.5
D034 Hexachlorobutadiene 3.0
D008 Lead 5.0
D013 Lindane 0.4
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

Waste Codes Contaminant Regulatory Level (mg/L)
D039 Tetrachloroethylene 0.7
D015
Toxaphene 0.5
D040 Trichloroethylene 0.7
D041 400.0
2,4,5-Trichlorophenol
D042 2,4,6-Trichlorophenol 2.0
D017 2,4,5-TP (SIlvex) 1.0
D043 Vinyl Chloride 0.2
Maximum Concentration of Contaminants for

the Toxicity Characteristic 40 CFR 261.24
Regulatory Level
Waste Code Contaminant (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 Metals

D012 - D017 Pesticides
D018 - D043 Organics
Identifying Waste
Being able to identify a waste can help you identify the

degree of danger involved. Use the following process to
identify 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 wastes

are 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 - Sole

Active 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 small

amounts. These wastes are regulated the same way as large
amounts of other hazardous wastes. If a company produces
as little as 1 kilogram (2.2 lbs) of acutely hazardous wastes
in a calendar month, or stores more than that amount for
any period of time, it is subject to all of the regulations that
apply to generators of more than 1,000 kilograms per
calendar month.

If the waste is not listed or land disposal restricted (40 CFR

262.11(c)), then it must be determined if the waste presents
one of the four characteristics discussed earlier.
Superfund Amendments and

Reauthorization Act
(SARA TITLE III)
SARA became law on October 17, 1986. SARA, also
known as the Emergency Planning and Community Right-
to-Know Act (EPCRA) was written to provide state and
local governments and the public with information concern-
ing potential chemical hazards present in the community.
SARA establishes requirements for industry regarding
emergency planning and “Community Right-to-Know”
reporting on hazardous and toxic chemicals. This law
builds on the EPA’s Chemical Emergency Preparedness
Program (CEPP). SARA Title III is intended to help
communities access information and thus better deal with
the presence of hazardous chemicals and releases of those
chemicals into the environment. Through SARA, states
and communities must work together with facilities to
improve chemical safety and protect public health. SARA
has four major provisions or sections: emergency planning;
emergency release notification; Community Right-to-Know
reporting requirements; and toxic chemical release inven-
tory.
Section 301-303: Emergency Planning
SARA requires the governor of each state to designate a

State Emergency Response Commission (SERC). SERCs
include public agencies involved in the environment,
natural resources, emergency services, public health,
occupational safety, and transportation. SERCs must also
have designated local emergency planning districts and
appointed Local Emergency Planning Committees. LEPCs
include elected state and local officials, police, fire, civil
defense, public health officials, environmental, hospital,
and transportation officials as well as facility representa-
tives. Finally, section 301-303 requires the development of
Emergency Response Plans by the LEPC.

Section 304: Emergency Release

Notification
Facilities must notify the LEPC (and consequently the

SERC) of any possible environmental release of specific
chemicals. The specific chemicals referred to in SARA
Title III are found on the following lists: Extremely Haz-
ardous Substance List (40 CFR 355); Reportable Quantity
List (CERCLA Section 103(a)). Emergency notification
must 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 written

follow-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 chemicals
to the SERC, LEPC, and local fire department. If facilities
choose to supply only a list, the list must include very
specific information regarding the health, fire, reactivity
hazards, 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 were
present at or above specific threshold quantities. The
specific threshold quantities are 500 pounds for extremely
hazardous substances and 10,000 pounds for all other
hazardous 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 toxic

chemicals which require emissions reporting. These report-
ing requirements are known as Form R. Facilities subject to
Section 313 are required to submit a Toxic Chemical Re-
lease Inventory Form for specified chemicals. Form R
notifies public and governmental agencies about routine
releases (releases that occur as a result of daily production
use). Form R applies to facilities of ten or more employees
with Standard Industrial Classification (SIC) codes 20
through 39, and that manufacture, process or otherwise use
a toxic chemical in excess of specified threshold quantities.
Form R is completed on an annual basis and is submitted by
July 1.

SUMMARY OF NOTIFICATION/REPORTING REQUIREMENTS UNDER SARA TITLE III
EMERGENCY FACILITY EMERGENCY MSDS CHEMICAL TOXIC
EMERGENCY RELEASE SUBMISSION INVENTORY CHEMICAL
Student Text
PLANNING
NOTIFICATION COORDINATOR NOTIFICATION [SECTION [SECTION 312] RELEASE
[SECTION 302] NOTIFICATION [SECTION 3D4 + 311] [SECTION 313]
[SECTION 303] CERCLA 103]
FACILITIES Any facility w/ Any Facility w/ Any Facility With Any Facility Any Facility Industry in SIC
ADDRESSED Extremely Haz. Extremely Haz. Releases Above Required By Required by 20-39 With 10 or
Substances Above Substances Above Reportable OSHA to Have a OSHA to Have a More Full Time
Threshold Planning Threshold Planning Quantifies (RQ) MSDS MSDS Employees
Quantities (TPQ) Quantities (TPQ)
DUE DATE May 17, 1987 September 17, 1987 Immediately October 17, 1987 March 1 For July 1 For
Previous Previous
Calendar Year Calendar Year
FREQUENCY One Time (For New One Time or When Oral: At Time of One Time (For Annual Annual
EHS Chemical Coordinator Changes Release. New Chemicals,
Update w/in 60 Written: Rept. as Update w/in 90
Days) Soon as Practicable Days)
REPORTING TPQ NQ Max. Amt. on Max. Amt. on Site Annual Tolls:
TPQ
THRESH- Site 10,000 // or 10,000 // or if •Mfr./Pro-
EHS, 500 lbs. or EHS 500 lbs. or cess=25,000 lbs.
OLD
TPQ If Lower TPQ If Lower •Otherwise
Used= 10,000 lbs
REFERENCE Extremely Hazardous Not List Specific CERCLA List & Chemicals Chemcials Toxic Chemcial
LIST Substances List (360 SERC/LEPC Can Extremely Hazard- Needing MSDS Needing MSDS List (328
Chemicals) Required for Planning ous Substance List (No List) (No List) Chemcials)
ORGANIZATIONS SERC LEPC •Nat. Resp. Center •SERC •SERC •EPA
RECEIVING (Oral) •LEPC •LEPC •State Degee
INFORMATION •SERC/LEPC •Fire Dept •Fire Dept
(Oral/Writ)
FORM No Specific Form No Specific Form No Form, But MSDS or Chem Tier I or Tier II Form R
REQUIRED Inform Specific List
IAFF Training for Hazardous Materials: Technician©
1-81
Comprehensive
Environmental Response
Compensation and Liability
Act (CERCLA)
The Comprehensive Environmental Response Compensa-
tion and Liability Act, known as CERCLA, was passed in
December 1980 and amended in 1986. This Act provides
federal authority to respond to environmental hazards posed
by abandoned disposal sites, and provides the resources to
clean up those sites. This Act established the reporting
requirements for the release of hazardous substances and
set up a taxing system to fund site clean-ups.
In addition, CERCLA introduced the term “hazardous

substance.” A hazardous substance is a reportable quantity
of specific materials. In fact, the reportable quantity (RQ)
table was first introduced by CERCLA. CERCLA deemed
specific quantities of certain materials dangerous to public
health and the environment. Quantities are listed in the RQ
table on the far right. Should an amount in excess of the
RQ be released into the environment, the responsible
facility has less than 24 hours to notify federal authorities.
The DOT has adopted RQs. Consequently, if an amount in
excess of the reportable quantity is found in any single
container, then an RQ must appear on the container label
and 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 label
or shipping paper.
Toxic Substance Control Act

(TSCA)
The office of Toxic Substances Control regulates specific
substances that are hazardous by some measure, but are not
necessarily regulated by other agencies. This regulation
covers asbestos, PCB-containing materials, and the
premanufacture notice by industry for new materials.
Clean Air Act (CAA)

The primary purpose of the Clean Air Act is to prevent or
minimize pollution. Congress passed this regulation to
encourage and promote pollution prevention. This regula-
tion is quite lengthy and details information requirements
for 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 for

responders 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 a
chemical that may reasonably be anticipated to cause death,
injury, or serious adverse effects to human health or the
environment. The basis for the list of chemicals comes
from the Emergency Planning and Community Right to
Know Act of 1986 (EPCRA). This law contains a list of
Extremely 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 an
accidental release of a hazardous substance.
Transportation of
Hazardous Waste
The Department of Transportation regulates movement of
hazardous materials in commerce, by any mode of transpor-
tation. DOT also regulates all hazardous wastes in the
hazardous 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 relative
to transportation. Remember EPA, OSHA, and DOT all
have very specific and different classification rules.

As stated earlier, a hazardous material is something

which has been determined by the DOT to be “...capable of
posing an unreasonable risk to health, safety, and property
when transported.” Materials designated as “hazardous” by
the DOT are listed in the Hazardous Materials Table, which
can be found in 49 CFR 172.101. Materials are listed in
alphabetical order in accordancewith their proper shipping
names. The DOT has included all hazardous waste by
definition as a hazardous material. Consequently, anything
regulated by the EPA as a hazardous waste must be shipped
according to the DOT hazardous material regulations.
NOTE: In December 1994, approximately 33% of

the Hazardous Material Table (49 CFR
172.101) was changed under Docket
HM215A [Vol. 59, No. 249, Thursday,
December 29, 1994].
The RCRA regulations require a “special” shipping paper

for hazardous waste. This document may change state to
state, but the general information remains the same. The
manifest serves two purposes. First, it tracks where the
waste came from, where it is going, and who moved it.
Second, it identifies the materials for emergency responders.
Activity

Hazard Identification
OSHA defines a “hazardous chemical” as any chemical that
poses a health hazard or a physical hazard to workers
during use. Furthermore, OSHA defines the tems health
hazard and physical hazard in the Hazard Communica-
tion Standard.
“Health Hazard means a chemical for which there is statistically

significant evidence based on at least one study conducted in
accordance with established scientific principles that acute or
chronic health effects may occur in exposed employees. The
term ‘health hazard’ includes chemicals which are carcinogens,
toxic or highly toxic agents, reproductive toxins, irritants, corro-
sives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents
which 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 compressed
gas, explosive, flammable, an organic peroxide, an oxidizer, py-
rophoric, unstable (reactive) or water reactive.”
Hazard Communication protects worker safety by ensuring

that chemical manufacturers convey to their customers and
employers convey to their employees the hazards associated
with using, working around and exposure to hazardous
chemicals in the work place. This is achieved through a
written program, labeling, Material Safety Data Sheets, and
employer training. Put more simply, hazards are identified
by the use of:
• OSHA, EPA, and DOT markings, labels, and

placards
• Material Safety Data Sheets
• Signs
• Training
One means of identifying potential health and physical

hazards is through the labeling required by OSHA under
the Hazard Communication (“Right-to-Know”) standard.
Both the label and the MSDS include information on the
hazards 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 for

ensuring 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 required

to provide, upon request, any additional information re-
quested about a specific hazardous material. A chemical
manufacturer, however, may declare the ingredients of a
compound a “trade secret”. In this case, if an accident
occurs where this information is vital, the manufacturer is
required to relinquish all information. The assumption is
that the trade secret in question will not be divulged.
The employer is required to maintain all labels on the

containers. Labels should be legible, in English, and
prominently displayed or readily available.
Labeling Systems
There are several labeling systems approved for use in

industrial settings. The three most common labeling
systems are the:
• HMIS
• NFPA
• DOT system

Hazardous Material
Identification System (HMIS)
The HMIS (designed by the National Paint and Coating
Association) is a comprehensive system for hazardous
materials identification. This system conveys chemical
identity by chemical or common names, code numbers, or
other descriptive terms which clearly identify the material.
The acute health, flammability, and reactivity hazards are
communicated by numerical ratings inserted onto the label
itself. The description of the numerical Hazard Index (HI)
is shown as follows:
4 Extreme Hazard
3 Serious Hazard
2 Moderate Hazard
1 Slight Hazard
0 Minimal Hazard
These designations will be written with indelible ink on

each section of the label (Health, Flammability, Reactivity).
Information is obtained from the MSDS or other sources
acceptable to OSHA.
Health Hazard or Blue Section
4 Extreme Highly Toxic - May be fatal on

short term exposure. Special
protective equipment required.
3 Serious Toxic - Avoid inhalation or skin
contact.
2 Moderate Moderately Toxic - May be
harmful if inhaled or absorbed.
1 Slight Slightly Toxic - May cause slight
irritation.
0 Minimal All chemicals have some degree
of toxicity.

Fire Hazard or Red Section
4 Extreme Extremely flammable gas or

liquid, Flash Point below 73° F.
3 Serious Flammable - Flash Point 73° F to
100° F.
2 Moderate Combustible - Requires moderate
heating to ignite. Flash Point
100° F to 200° F.
1 Slight Slightly Combustible - Requires
strong heating to ignite.
0 Minimal Will not burn under normal
conditions.
Reactivity Hazard or Yellow Section
4 Extreme Explosive at room temperature.
3 Serious May explode if shocked, heated

under confinement or mixed with
water.
2 Moderate Unstable, may react if mixed
with water.
1 Slight May react if heated or mixed
with water.
0 Minimal Normally stable, does not react
with water.
Personal Protective Equipment

or White Section
Recommended personal protective equipment (PPE) is

identified in this section by a letter. The white bar indicates
what 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 be
referenced. If PPE requirements are uncertain or assistance
is needed, see the MSDS.

National Fire Protection

Association (NFPA) Diamond
The NFPA Diamond is a labeling system that incorporates
the use of four diamonds combined in one central diamond.
NFPA 704 M is a standardized system that uses numbers
and 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 the

material, the numbers from 0 - 4 are used. The number
four (4) indicates the maximum or most severe hazard.
NFPA ratings for individual chemicals can be found in the
NFPA “Guide to Hazardous Materials”.
Health Hazard or Blue Section
4 Deadly
3 Extreme Danger
2 Hazardous
1 Slightly Hazardous
0 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 Detonate
3 Shock and Heat May Detonate
2 Violent Chemical Change
1 Unstable If Heated
0 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 in
the white block:
OX = Oxidizer
W = Use no water
ACID = Acid
ALK = Alkali
COR = Corrosive

U. S. Department of
Transportation (DOT)
Hazard Identification System

The U. S. DOT’s Hazardous Materials Transportation
Administration regulates over 1,400 hazardous materials.
The DOT requires labels on small containers and placards
on tanks and trailers. These placards and labels indicate the
nature of the hazard.
Classification used for placards and labels is based on an

International Classification System. Materials are de-
scribed using hazard class numbers that are found in the
bottom corner of a DOT placard or label. The DOT num-
bering system has no relationship to the NFPA or HMIS
numbering 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 DOT
regulations, 49 CFR 172.101. This ID number can be
found on shipping papers, the hazardous waste manifest,
and hazardous waste markers. Once the 4-digit number is
obtained, the North American Emergency Response Guide-
book can be consulted. This book outlines recommended
methods and precautions for responding to a release of each
hazardous materials with a 4-digit ID number.
Material Safety Data Sheets

Chemical manufacturers and importers are required to
obtain or develop Material Safety Data Sheets (MSDSs)
and supply them to the employer.
The employer is required to have MSDSs available for all

hazardous chemicals used in the work place and must make
them 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 on

MSDSs. This standard will require a consistent layout of
MSDSs including information presented in the same
section and the same order on all MSDSs, regardless of the
product manufacturer.

Pre-Incident Planning
As we have seen in the previous sections of this chapter, the
DOT, OSHA, and EPA have many regulatory requirements,
many of which appear to overlap. Yet the agencies require
separate and distinct reporting requirements, labels, ship-
ping papers/hazardous waste manifests, and emergency
plans.
Pre-planning is nothing new to the fire service. Most

departments conduct in-service pre-plan activities on a
routine basis. These pre-plans have traditionally addressed
information such as building contacts, utilities shut-offs,
type of construction, and resources (i.e. water, engines,
ladders) needed to control a fire incident involving the
building.
This section does not address the basic pre-plan informa-

tion; instead, it addresses some of the new regulations that
industry must comply with, and how these regulations will
actually assist the fire service. This section will also
provide some sample forms which you can use or modify to
fit your department’s needs.
SARA Requirements
As we discussed in the OSHA section of this module, the

SARA Title III regulation was a major asset for the fire
service community. This regulation made facilities comply
with Emergency Planning notifications, designate facility
emergency coordinators, make notification in the event of a
release of a chemical, and provide information to respond-
ers such as MSDSs. SARA Title III also required states
and local authorities to conduct emergency planning for
SERCs and LEPCs respectively.

Final Rules
Integrated Contingency Plan
In addition to SARA requirements, other federal agencies

require plans to be written. Two fairly recent final rules
published in the Federal Register are going to make haz-
ardous materials pre-planning for the fire service much
easier.
The first rule, titled “The National Response Team’s

Integrated Contingency Plan Guidance” is a collaborative
effort 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 Contingency

Plan (ICP) or “One-Plan” allows a facility to write one
plan and comply with the written plan requirements from
all of the above listed agencies. The Federal Register
summarizes the one-plan as follows “...this guidance is
intended to be used by facilities to prepare emergency
response plans. The intent of the NRT is to provide a
mechanism for consolidating multiple plans that facilities
may have prepared to comply with various regulations into
one functional emergency response plan or integrated
contingency plan.”
This plan will give the hazardous materials responders

valuable information regarding the types and quantities of
materials on site, the facility’s response capabilities, and
any equipment on site or through contractors which is
available for use to control a release from the facility.

Risk Management Plan
The second rule, titled “Accidental Release Prevention

Requirements: Risk Management Programs Under the
Clean Air Act, Section 112 (r) (7);...” will address very
specific 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 accidental
releases to the air and mitigate the consequences of such
releases by focusing prevention measures on chemicals that
pose the greatest risk to the public and the environment.”
The Risk Management Program requires stationary sources

to develop and implement a risk management program
which 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 of
a Risk Management Plan (RMP). This plan must also be
submitted to state and local authorities and made available
to the public.
The main component of the RMP is to evaluate Worst Case

Scenarios (WCS) involving the release of a regulated
substance. The WCS is defined “...as the release of the
largest quantity of a regulated substance from a vessel or
process line failure, including administrative controls and
passive mitigation that limit the total quantity involved of
the release rate. For most gases, the WCS assumes that the
quantity is released in ten minutes. For liquids, the sce-
nario assumes an instantaneous spill.” In addition to the
gas release, if the material is flammable, the WCS includes
a resulting vapor cloud explosion and fire ball effects to the
surrounding community.
The RMP is a complex document which includes vulner-

able populations, off-site consequences of the release, the
concentrations of materials released at downwind distances,
and the available facility control method which may limit
or 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 need
to develop an RMP.

In the final guidance, the “EPA encourages local emergency

planners, fire departments, and others who use tools such as
CAMEO/ALOHA or other modeling techniques to assist
businesses in their community who may need help in their
modeling efforts.”
Due to this rule, industry may be turning to the fire service

to assist in planning the response to the Worst Case Sce-
nario at a facility. Imagine if the information contained in
the RMP was available to the local hazardous materials
response team and the local fire department prior to an
incident at the facility. This pre-planning tool will be a
valuable asset to all first responders.
The RMP requirements are complex and will require

industry to work with the local jurisdiction in developing
the RMP and associated emergency response plans for
those incidents. This plan, coupled with the “One-Plan”
discussed earlier, will give first responders and hazardous
materials teams a tremendous amount of information to aid
in 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 containers
that could be used for hazardous materials
• DOT placards/labels or NFPA or HMIS markings (preferably for some incompatible

chemicals)
• 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 (some
may 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 hazardous
materials in storage and transportation situations. Stage an “incident” (set up on a road or in a
fixed location) and position the containers around the scene. Open some of them to simulate a
breach.
Briefly describe the “incident” and assign groups of students to fill the roles of the first-in engine
company, the hazardous materials team, and the incident commander. Initially, give the students
only the information they would be told by the dispatcher. As the incident progresses, provide
the students with the additional information they might find at an actual scene, such as the
shipping papers or MSDSs.
As the students work through the exercise ask the following questions, focusing on regulations
that 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. The
topics 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 actions
or habits based on the information covered in this module? Listed below are some suggested
actions. Some you may already do, and others may not fit your work environment. If there are
actions you have not done in the past, do you think you will begin doing them as a result of this
training?
1. Look for and interpret DOT placards and labels and other markings at the scene of a
hazardous 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, Red
Fuming.
Primary Label ____________________

Subsidiary Label ____________________
4. When shipping sulfuric acid by highway in 55-gallon containers, what special

provision(s) apply?


Oxidizer Case Study Activity 2
May 25, 1990

11:00 a.m.
First responding fire fighters are called to a reported fire on an interstate highway. The initial
response includes two engine companies, two EMS units, a heavy rescue squad and a battalion
fire 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 moving
slowly 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 of
the incident location.
The first engine company on the scene reports a straight-body truck on the shoulder of the
northbound lanes with the cargo compartmen involved in fire. The driver meets the engine
company 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 fire
may 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 of
small 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:
Research
Confirm site control and confirm zones
Complete size-up
Create action plan
Create necessary sectors: HM, OPS, Staging, EMS, and Rehab
Gather sources
Initiate limited evacuation
Begin fire fighting actions using remote streams
Decontaminate exposed first responders
Provide for remote containment runoff
Stabilize post-fire incident
Plan for hand-off and termination


Hazard Class Activity 3

1. A division 4.2 material is
a. Dangerous When Wet
b. Oxidizer
c. Spontaneously Combustible
2. A division 5.1 material is:

a. Organic Peroxide
b. Oxidizer
c. 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 the

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


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 materials
that 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 packed
with closures up and marked with or .


Segregation Table Activity 5
1. True / False Oxidizers and materials that are Dangerous When Wet can be shipped
together without segregation.
2. True / False Corrosives and materials that are Poison by Inhalation can be shipped
together.
3. True / False Ammonia nitrate can be stored with Explosives 1.1.
4. True / False Spontaneously Combustible materials can be transported with Flammable

Gases.
5. True / False Organic Peroxides must be segregated when stored with Flammable
Gases.
6. True / False Corrosive Liquids must be segregated when shipped with Flammable
Liquids.
7. True / False Radioactive materials must be segregated when shipped with Flammable
Gases.
8. True / False Poison Gas (other than Zone A) can be shipped with materials that are
Dangerous When Wet.


Regulatory Agency Activity 6
For each of the acronyms below, identify the letters, name the responsible regulatory agency, and
match the acronym to its appropriate definition.
1. RCRA:
Responsible Agency:
Definition:
2. 49 CFR:
Responsible
Definition:
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 required
for 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 hazardous
waste operations.
Paragraph C - Site Characterization. Identification of specific site hazards are required and
the 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 the
purpose of controlling employee exposure to hazardous substances before clean-up operations
begin.
Paragraph E - Training Requirements for Site Workers. The amount of training an employee
shall receive before working on a site is detailed herein. Paragraph E also indicates the type of
training and certification needed to work on a clean-up site where employees may be exposed to
hazardous substances and safety or health hazards.
Paragraph F - Medical Surveillance. Since only specific employees are covered under this
paragraph, 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 the
physician’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 protect
employees from exposure to hazardous substances are outlined in paragraph G. The purpose of
this paragraph is to protect employees from safety and health hazards.
Paragraph H - Monitoring. Air monitoring is discussed herein. Requirements such as when is

air 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 inform

employees, contractors, and subcontractors of the nature, level, and degree of exposure that
could 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, and
transported. Possible ergonomic injuries should also be considered.
Paragraph K - Decontamination. Paragraph K describes the phases of decontamination such

as 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, and
procedures for handling emergency incidents.
Paragraph M - Illumination. The requirements for minimum illumination are described in this
paragraph.
Paragraph N - Sanitation. Paragraph N describes sanitation requirements at temporary work

places which include potable and non-potable water, toilet facilities, food handling, washing
facilities, 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 programs

required for workers who are employed at treatment, storage and disposal (TSD) facilities. These
programs include:
A. Safety and Health Program

B. Hazard Communication Program
C. Medical Surveillance Program
D. Decontamination Program
E. New Technology Program
F. Material Handling Program
G. 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 successful
completion 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; and
PPE and emergency equipment.
In addition to the above elements, the ERP must also have details about training
and 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.
Alaska
Arizona
California
Connecticut (for state and local government employees only)
Hawaii
Indiana
Iowa
Kentucky
Maryland
Michigan
Minnesota
Nevada
New Mexico
New York (for state and local government employees only)
North Carolina
Oregon
Puerto Rico
South Carolina
Tennessee
Utah
Vermont
Virginia
Virgin Islands
Washington
Wyoming

Non-State Plan States

State and local government employees of the following states are covered by the EPA worker protection
regulations. Private sector and federal fire fighters in the following states/territory are covered by federal
OSHA worker protection regulations.
Alabama Missouri
Arkansas Montana
Colorado Nebraska
Delaware New Hampshire
District of Columbia New Jersey
Florida North Dakota
Georgia Ohio
Guam Oklahoma
Idaho Pennsylvania
Illinois Rhode Island
Kansas South Dakota
Louisiana Texas
Maine West Virginia
Massachusetts Wisconsin
Mississippi

Appendix D
Sample Material Safety Data Sheet
and MSDS Checklist


MDSD—Toluene
RANDOLPH PRODUCTS — TOLUENE

MATERIAL SAFETY DATA SHEET
FSC: 6810
NIIN: 00F000177
Manufacturer’s CAGE: 77672
Part No. Indicator: A
Part Number/Trade Name: TOLUENE
===========================================================================
General Information
===========================================================================
Item Name: /
Company’s Name: RANDOLPH PRODUCTS CO.
Company’s Emerg Ph #: 201/438-3700
Record No. For Safety Entry: 001
Tot Safety Entries This Stk#: 001
Date MSDS Prepared: 01JAN85
Safety Data Review Date: 20APR84
MSDS Serial Number: BBGBJ
===========================================================================
Ingredients/Identity Information
===========================================================================
Proprietary: NO
Ingredient: TOLUENE (SARA III)
Ingredient Sequence Number: 01
Percent: 100
NIOSH (RTECS) Number: XS5250000
CAS Number: 108-88-3
OSHA PEL: 200 PPM/150 STEL
ACGIH TLV: 50 PPM; 9293
===========================================================================
Physical/Chemical Characteristics
===========================================================================
Boiling Point: 230F
Vapor Density (Air=1): >AIR
Evaporation Rate And Ref: <1 ETHER=1
Percent Volatiles By Volume: 100
===========================================================================
Fire and Explosion Hazard Data
===========================================================================
Flash Point: 41F T.C.C.
Lower Explosive Limit: 1.2
Extinguishing Media: SAND, FOAM, CO2
Special Fire Fighting Proc: DRY CHEMICALS, FOAM
Unusual Fire And Expl Hazrds: NONE
===========================================================================
Reactivity Data
===========================================================================
Stability: YES
Cond To Avoid (Stability): FLAME
Hazardous Poly Occur: NO

===========================================================================
Health Hazard Data
===========================================================================
Signs/Symptoms Of Overexp: VAPORS MAY CAUSE DROWSINESS, HEADACHE,
DIZZINESS AND IRRITATION OF EYES, NOSE AND THROAT
Emergency/First Aid Proc: REMOVE TO FRESH AIR, FLUSH EYES WITH LOTS OF
WATER, CONSULT PHYSICIAN.
===========================================================================
Precautions for Safe Handling and Use
===========================================================================
Steps If Matl Released/Spill: REMOVE ALL SOURCES OF IGNITION, WEAR
APPROVED RESPIRATOR, CONTAIN SPILL WITH INERT SSTANCE (SAND, DIRT), PUT
MIXTURE IN CONTAINERS FOR DISPOSAL. KEEP SPILL T OF SEWERS AND OPEN BODIES
OF WATER.
Waste Disposal Method: LAND FILL—ACCORDING TO CURRENT LOCAL, STATE AND
FEDERAL REGULATIONS.
Precautions-Handling/Storing: KEEP AWAY FROM HEAT, FLAME. KEEP AWAY FROM
CHILDREN.
===========================================================================
Control Measures
===========================================================================
Respiratory Protection: MESA/NIOSH APPROVED RESPIRATOR WHERE VAPOR
CONCENTRATES.
Ventilation: EXPLOSION-PROOF EXHAUST VENTILATION AT POINT OF RELEASE
Suppl. Safety & Health Data: PARK PLACE EAST CARLSTADT, NJ 07072
===========================================================================
Transportation Data
===========================================================================
===========================================================================
Disposal Data
===========================================================================
Disposal Data Review Date: 88055
Rec # For This Disp Entry: 01
Tot Disp Entries Per NSN: 001
Landfill Ban Item: YES
Disposal Supplemental Data: PARK PLACE EAST CARLSTADT, NJ 07072 IN CASE OF
ACCIDENTAL EXPOSURE OR DISCHARGE, cONSULT HEALTH AND SAFETY FILE FOR
PRECAUTIONS.
1st EPA Haz Wst Code New: U220
1st EPA Haz Wst Name New: TOLUENE; METHYLBENZENE
1st EPA Haz Wst Char New: TOXIC (T)
1st EPA Acute Hazard New: NO
2nd EPA Haz Wst Code New: D001
2nd EPA Haz Wst Name New: IGNITIBLE
2nd EPA Haz Wst Char New: IGNITABILITY
2nd EPA Acute Hazard New: NO

===========================================================================
Label Data
===========================================================================
Label Required: YES
Label Status: G
Common Name: TOLUENE
Special Hazard Precautions: VAPORS MAY CAUSE DROWSINESS, HEADACHE,
DIZZINESS AND IRRITATION OF EYES, NOSE AND THROAT
Label 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 / Gas
Color:________________________________ 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 / No
PEL:____________ TLV/TWA:_____________ IDLH:______________
LC50:_________________
Ingestion Hazard: Yes / No
LD50:___________________ mg/kg
Absorption Hazard: Yes / No
Skin:____________ Eyes:__________________
Carcinogen: Y / N Mutagen: Y / N Teratogen: Y / N
Hazardous to Aquatic Life: Y / N
Other:____________________________________________________________________________
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:_____________________________________________________________________


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Student Text IAFF Training for Hazardous Materials: Technician©

Module 1: Regulations 1-1

1-2 Module 1: Regulations

Module 1: Regulations 1-3

1-4 Module 1: Regulations

1-6 Module 1: Regulations

3. Which of the following organizations issues mandatory standards?

5. OSHA’s Hazard Communication Standard is:

6. Which of the following organizations issues hazard classes and divisions?

Module 1: Regulations 1-7

7. Un identification numbers indicate that a chemical may be shipped:

8. Hazardous materials that must always be placarded, regardless of quantity, are:

9. Title 49 in the Code of Federal Regulations includes all:

10. The Superfund Amendment and Reauthorization Act is administered by:

1-8 Module 1: Regulations

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 known

These federal agencies communicate their regulations in the

Module 1: Regulations 1-9

Federal Department Title Number

Environmental Protection Agency 40

Department of Labor (OSHA) 29

Additionally, the federal government prints the Federal

State Regulatory Agencies

The DOT and EPA turn over the regulation of hazardous

1-10 Module 1: Regulations

Title Titles are written in numbers (usually

Chapter Chapter numbers are written in

Part Parts are written in numbers. Part

Subpart Subparts are written in capital letters

Section Sections are written as numbers

Paragraph Paragraphs are written using small

Subparagraphs Subparagraphs are written as small

Module 1: Regulations 1-11

As indicated earlier, each title number is assigned based on

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

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

Each of the three federal agencies discussed in this module

1-12 Module 1: Regulations

Refer to the Straight Bill of Lading on the following page to

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 the

A hazardous materials employee is

A hazardous materials employee is also

Module 1: Regulations 1-13

employer and who in the course of employment di-

Job functions under this requirement are as follows:

On May 15, 1992, the Research and Special Programs

In addition, the Performance-Oriented Packaging Standards

• Classified, named, marked, placarded, and labeled in

1-14 Module 1: Regulations

The major purpose of POPS is to identify materials that

• To transport hazardous materials in accordance with UN

• To simplify the hazardous materials transportation regu-

• To reduce the quantity of DOT regulations concerning

• To limit the quantity of exemptions issued by DOT

Transporters and packaging manufacturers are now re-

Module 1: Regulations 1-15

DATE COMPLIANCE SCHEDULE

October 1, 1991 Explosives must be shipped in accordance with POPS.