When You Must Provide Shipping Papers with Return Cargo Tanks [49 CFR 171.8]
Packages that contain residues of hazardous materials are regulated for transportation in substantially the same way as if they are full. When you receive a delivery of a hazardous material transported in a cargo tank—defined at 49 CFR 171.8 as a bulk packaging intended to carry liquids or gases that is permanently attached to or forms a part of a motor vehicle—you must determine if you are required to provide a shipping paper for the cargo tank when it leaves your facility.
To determine if the cargo tank return shipment must be accompanied by a shipping paper, you must first determine if you are the offeror of the residue. An offeror (or shipper) is defined at 49 CFR 171.8 as any person performing pre-transportation functions. Pre-transportation functions are discussed at 49 CFR 171.1(b) as including, but not being limited to:
- Classifying materials as regulated
- Selecting or packing containers for shipment
- Marking or labeling containers for shipment
- Filling out shipping papers and/or hazardous waste manifests
If a cargo tank of hazardous materials is unloaded at your facility—and the carrier remains present and leaves immediately after unloading—the cargo tank remains in transportation. In this scenario, you are a receiving facility that has not performed any pre-transportation functions—and you are not the offeror of the residue shipment. In this scenario, the original shipping paper is sufficient for the return cargo tank shipment because the carrier remained present, the cargo tank remained attached to the vehicle, and the cargo tank is considered to be in transportation and is covered by the active shipping paper throughout the process. In this scenario, it would be prudent for you to ensure that the carrier retains a copy of the original shipping paper when they leave your site.
If a cargo tank is delivered to your facility, it is unloaded without the driver present, and it is then offered at a later time as a residue shipment—it has left transportation. In this scenario, you are the offeror of the hazardous material residue in the cargo tank and you must provide a shipping paper with the return shipment.
There is an exception, however, for the Shipper’s Certification statement on the shipping paper. 49 CFR 172.204(b) states that there is no certification statement required (except for hazardous wastes) for a cargo tank that was supplied by the carrier.
Learn more about how to ship hazardous materials properly and meet your mandatory training requirements by attending Environmental Resource Center’s DOT Hazardous Materials Training: The Complete Course seminar, DOT Hazardous Materials Training: The Complete Course – Webcast, or DOT Hazardous Materials Update – Webcast.
Highest Rated DOT Hazmat Training
Training is required for all employees who the DOT classifies as Hazmat Employees. Anyone responsible for the safe transportation of hazardous materials, such as those who are involved in packaging, labeling, loading, unloading, completing shipping papers, or providing emergency information must be trained. Environmental Resource Center training is available on-site, and at conveniently located seminars, instructor-led webcasts, or self-paced online training.
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Upcoming Hazardous Material Transportation Webcasts
Environmental Resource Center’s live instructor-led webcast training is the best way to get the training you need—without leaving your office. Stay up-to-date with the latest regulations that can impact your shipments and get site-specific questions answered by our experienced, expert instructors.
How to Ship Dangerous Goods by Vessel – IMDG Code Webcast
March 1
Gain an in-depth understanding of the latest requirements for shipments of dangerous goods by sea—in accordance with the International Maritime Dangerous Goods (IMDG) Code. The DOT and International Maritime Organization (IMO) require initial and recurrent training every three years for personnel involved in the shipment of dangerous goods by vessel. This course meets both initial and recurrent IMDG training requirements.
DOT Hazardous Materials Training – The Complete Course Webcast
March 14
All personnel involved in the shipment of hazardous materials (including hazardous waste) are required to receive initial DOT hazardous materials training and recurrent training every three years. This course fulfills your initial and recurrent training requirements.
IATA: How to Ship Dangerous Goods by Air – The Complete Course Webcast
March 15
The International Air Transport Association (IATA) requires initial training and recurrent training every two years for all personnel involved in the shipment of dangerous goods by air. This live online training will prepare you to ship dangerous goods according to the latest requirements of the IATA Dangerous Goods Regulations (DGR), including the changes that went into effect on January 1, 2018. This course fulfills your initial and recurrent IATA training requirements and gives you the tools you need to comply with the regulations and avoid rejected shipments.
DOT: How to Ship Hazardous Materials by Ground – Update Webcast
March 21, April 4
The DOT requires initial hazardous materials training and recurrent training every three years for all personnel involved in the shipment of hazardous materials (including hazardous waste). This course fulfills your DOT recurrent training requirements.
How to Ship Batteries by Ground & Air – Webcast
March 22
If you ship batteries by ground or air, you must comply with stringent DOT and IATA regulations for battery shipments. Virtually all types of batteries are regulated, including lithium, lead-acid, nickel cadmium, and metal hydride alkaline. And the rules apply not only to batteries, but also to equipment or vehicles that contain batteries as well as batteries packed with equipment. This course meets both DOT and IATA initial and recurrent training requirements for personnel involved in the classification, packaging, marking, labeling, or shipment of batteries.
IATA: How to Ship Dangerous Goods by Air – Update Webcast
April 5
IATA requires initial dangerous goods training and recurrent training every two years for all personnel involved in the shipment of dangerous goods by air. This live online IATA Update training will prepare you to ship dangerous goods according to the latest requirements of the IATA Dangerous Goods Regulations. This course fulfills your IATA recurrent training requirements.
DOT/IATA: How to Ship Dangerous Goods by Ground & Air – Webcast
April 19
If you ship dangerous goods by both ground and air, this live online course is the best way to meet your DOT (49 CFR 172.704) and IATA (DGR 1.5) training requirements in one day. This course meets both DOT and IATA initial and recurrent training requirements.
Webcast special offer:
- Register two attendees at full price and each additional person attends the same class for half price.
To view a complete list of Environmental Resource Center’s top-rated courses, go to www.ercweb.com/courses.
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Learn when it’s convenient for you. Environmental Resource Center’s self-paced online training makes it easy to learn how to comply with the latest regulations that can impact your facility, and meet your training requirements in our no-sweat online courses:
- DOT Hazardous Materials Training
- Reverse Logistics Shipments of Hazardous Materials
- How to Ship Batteries by Ground and Air
- How to Ship Dry Ice by Ground and Air
- How to Ship Consumer Commodities and Limited Quantities by Ground and Air
- How to Ship Bulk Hazardous Materials by Ground
- How to Ship Infectious Substances by Ground and Air
- How to Ship Medical Waste
- How to Manage Used Oil
- How to Manage Universal Waste
- How to Work Safely with Bloodborne Pathogens
- OSHA GHS Hazard Communication Standard
- EPCRA: Tier II Reports & Emergency Release Notifications
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