Two Hazmat Labels You Cannot Use Anymore

January 04, 2021
If you ship consumer commodities that are hazardous materials, such as paint, aerosols, bleach, or adhesives, you are probably familiar with the “ORM-D” marking, which was placed on the outside of the package to indicate that the shipment conformed to the requirements for consumer commodities.  Most of the other ORM marks expired years ago, and ORM-D has finally expired as well. This brings the U.S. closer to the international requirements for shipping dangerous goods.  That’s a good thing, since we ship many products to other countries, and it doesn’t make it easy when we mark packages one way for shipments within the U.S. and another way when we ship to other countries.  Beginning January 1, consumer commodities must be shipped with the Limited Quantity mark, which is depicted to the left. For shipments of limited quantities by air, you should use a label similar to the one depicted in this article, however it should have the letter “Y” in the center field. Details on this change can be found in the December 21 Federal Register.
Another label that has expired is the old U.S. version of the Class 9 miscellaneous hazardous material label.  The prior version had a horizontal line running across the label at its midpoint. Back in 2011, the DOT adopted the international version of this label that does not have the horizontal line.  However, the agency allowed the use of the old label to allow for the depletion of existing stocks.  Beginning on January 1, the old version of the label could no longer be used.
Need help labeling your products?  Are there differing requirements based on the size of the product, or where its distributed? Environmental Resource Center can determine the correct EPA, OSHA, DOT, CPSC, Proposition 65, and EU labels that apply.  For details, contact us at
New Year’s Resolutions
As you can imagine, if you don’t set out objectives for the year, you won’t meet them.  To help you get started, the following are some suggestions for your 2021 New Year’s EHS resolutions.  Hopefully, you’ll be thinking “we’ve already done that” for the majority of Environmental Resource Center’s 2021 New Year’s resolution suggestions:
  • Learn about and implement sustainability at your site and throughout your organization.
  • Ensure that environmental and safety responsibilities are on all employee job descriptions.
  • Update anything that has the potential to be outdated, such as SOPs, SDSs, emergency response plans, job safety analyses, risk management plans, SPCC plans, stormwater plans, confined spaces plans, permits, and training programs.
  • Review all of your SDSs with the goal of identifying products that are the most hazardous. Are they carcinogens, reproductive hazards, highly toxic, or do they have other significant hazards to your employees or customers. Closely evaluate the top 5 most hazardous products. Are there any safer effective substitutes? Any ways to mitigate their hazards? Can you work with your site design team or vendors to make those products safer?
  • Make a detailed list of every government regulation that applies to your facility: federal, state, and local. Ensure that department managers are aware of the regulations that apply to their departments. Have department managers certify in writing that their department is in compliance. Audit at least annually to validate compliance.
  • For products shipped internationally: confirm that your products meet all of the safety and environmental regulations that apply in each country where your products are distributed.
  • Because some states and localities have their own requirements: confirm that your products meet all of the safety and environmental regulations that apply in each state and local jurisdiction where your products are distributed.
  • Create a system that tracks pending and finalized domestic and international regulations that apply to your products.
  • Create a program to solicit suggestions from employees, vendors, and customers: how can we make our products safer, or more sustainable? Also solicit suggestions regarding the packaging of your products and how they are transported.
  • Investigate: are there any ways your products can be made safer for your customers, their employees, the environment?
  • Identify every type of accident or injury that could occur. Develop and implement procedures to prevent these events. Conduct realistic drills on how your site will respond to these events. Invite any outside parties that would assist in the response to participate in the drills.
  • Get rid of out unwanted and unneeded materials. See if any can be returned to vendors, listed on a waste exchange, recycled as scrap metal, or donated. Do the same for anything in your boneyard.
  • Ensure that your records management system could quickly identify every environmental and safety document. Digitize paper documents.  Archive outdated documents.  Discard documents that have aged past their regulatory and corporate life spans. Ensure that personnel retrieving documents won’t mistakenly retrieve outdated documents and think that they are current.
  • Evaluate the environmental and safety aspects of your supply chain: for raw materials, energy use, generation of GHG, worker safety, and waste.
  • Make your company attractive to environmentally and socially responsible investors.
  • Develop an environmental product declaration for each of your company’s products.
It's a long list, and you may have other important objectives to meet this year. Your consultants at Environmental Resource Center are here to help you meet your environmental, health, safety and transportation objectives.  Contact us at if there’s anything we can do to make 2021 your best year ever. And, if you have any highly pressing objectives, feel free to contact Brian Karnofsky, our company president, who will be happy to assist you. You can reach him at
Tips for Holiday Recycling
The holiday season has ended and now’s the time to take down the decorations and dispose of Christmas trees, packaging, wrapping and other items, including used or broken electronics. The Missouri Department of Natural Resources has a few suggestions to help with disposing of these items this holiday season.
Electronics (e-cycling): Strings of lights and pre-lit trees can be recycled. Also, if you received new electronics and would like to dispose of old or broken items, consider these options:
  • Check the electronic manufacturer’s website for mail-back options, or check your electronics store for take-back options.
  • Consider repurposing items by adding memory or making upgrades to old devices.
  • Donate used electronics to schools, nursing homes and other organizations that might need them for entertainment or training. Electronics manufacturers that sell products in Missouri usually have take-back programs in place. Check your local stores, libraries or electronic recyclers for recycling opportunities.
  • After you've reused or donated unwanted electronic equipment, help reduce the remaining electronic waste from this holiday season by e-cycling your worn out computers, cell phones, MP3 players, digital cameras, DVD players, gaming systems, TVs and other electronic items through e-cycle Missouri. An electronics recycler can remove potentially hazardous materials and reduce the amount of waste going into landfills.
  • See our online Registered Electronics Recycling Businesses List at and upcoming e-cycling events schedule at
Christmas trees, wreaths and other decorative greenery: Natural greenery makes beautiful Christmas decorations, but deciding what to do with them after the holidays can be challenging. Here are some tips:
  • Check with the tree farms and other retailers for take-back options.
  • Remove all of the decorations and trimmings; most are reusable and could contaminate the environment or harm wildlife.
  • Avoid burning trees and other greenery in wood stoves or fireplaces; the resins could cause a flue fire.
  • Compost or dispose trees in an environmentally safe manner.
  • For more details, see our online factsheet Christmas Tree Disposal at
Boxes and other packaging: Online shopping is rapidly gaining in popularity, especially during the COVID-19 pandemic. With this growing trend come heaps of cardboard boxes, packing and wrapping materials that can accumulate quickly and become difficult to manage. Following are some suggestions for dealing with waste packaging:
  • Flatten cardboard boxes to fit your garage or other storage space for future use, such as shipping or moving items.
  • You can also take these items to local recycling facilities. Call your Solid Waste Management District or check for recyclers using the Missouri Materials Management Directory found at
Food: The holidays can leave leftover food that can go to waste before we can eat it all. An average of nearly 40% of food is wasted in the United States, averaging about $1,600 per family annually. Here are a few ideas for dealing with holiday leftovers:
  • Prevent food waste and save some of your hard-earned dollars by transforming your leftover holiday food items into fresh meals for your household.
  • Search online for recipes for creative dishes using holiday leftovers. Learn more at: gov/foodwaste/faqs.
  • Guidance on how to safely handle holiday leftovers and other food safety information can be found at:
Get Your RCRA and DOT Training Online
To help you get the training you need, Environmental Resource Center has added a number of dates to our already popular live webcast training. Stay in compliance and learn the latest regulations from the comfort of your office or home. Webcast attendees receive the same benefits as our seminar attendees including expert instruction, comprehensive course materials, one year of access to our AnswerlineTM service, course certificate, and a personalized user portal on Environmental Resource Center’s website.
Upcoming hazardous waste and DOT hazardous materials webcasts:
EPA Eases Implementation of Heavy Duty Vehicle Regulations
On December 28, EPA published two actions regarding technical adjustments to improve testing procedures for vehicle and engine emissions programs. According to EPA, these amendments will increase compliance flexibility, improve harmonization with other requirements, increase clarity, correct errors, and remove outdated and unnecessary regulatory text.
“The Trump Administration continues its efforts to reduce the regulatory burdens on domestic industries that are vital to the American way of life,” said EPA Administrator Andrew Wheeler. “These changes help streamline EPA’s existing regulations while reducing the likelihood that manufacturers would need to duplicate certifications to comply with EPA, Canadian, and California standards.”
The first action is a final rulemaking that will reduce testing burden and improve accuracy of required emissions testing procedures for heavy duty vehicles and engines. The action also amends test procedures for exhaust emissions standards for light-duty vehicles, heavy-duty vehicles, highway motorcycles, locomotives, marine engines, other nonroad engines and vehicles, and stationary engines. Many of these updates will take effect for MY 2021.
EPA is also issuing a supplemental notice of proposed rulemaking (SNPRM) that would issue corrections, clarifications, flexibilities, and adjustment factors to improve the Greenhouse gas Emissions Model (GEM) compliance tool for heavy-duty vehicles. The proposed amendments concerning GEM included in this notice would be required for model year 2022 and later vehicles and optional for model year 2021. EPA is taking public comment on the supplemental notice of proposed rulemaking for 30 days after the notice is published in the Federal Register.
Final heavy-duty technical amendments:
Supplemental notice of proposed rulemaking:
EPA Finalizes First Greenhouse Gas Emissions Standards for Aircraft
EPA has finalized emissions standards for airplanes used in commercial aviation and large business jets. This action will align U.S. standards with the international carbon dioxide (CO2) emissions standards set by the International Civil Aviation Organization (ICAO), ensuring domestically manufactured aircraft remain competitive in the global marketplace. This final rulemaking also sets a precedent with the Trump Administration being the first to regulate greenhouse gas emissions from aircraft. Under President Trump, EPA has now finalized four regulations that will reduce greenhouse gases including the Affordable Clean Energy (ACE) rule, Safer Affordable Fuel-Efficient (SAFE) Vehicle rule, and New Source Performance Standards (NSPS) for Oil and Gas – the most in history.
“The U.S. leads the world in reducing greenhouse gas emissions and today’s historic action that finalizes the first-ever GHG standard for aircraft will continue this trend,” said EPA Administrator Andrew Wheeler. “This is the fourth concrete final regulation the Trump Administration’s pragmatic approach to climate action has produced meaningful results without unnecessarily sacrificing American jobs or important domestic industries like our aircraft manufacturers.”
The ICAO standards were developed with significant input from EPA, the Federal Aviation Administration (FAA), and U.S. and international aviation industries. Typically, three out of four aircraft manufactured in the U.S. are sold overseas. These standards will help ensure consistent standards across the world, and most importantly allow U.S. manufactured planes, such as commercial and large passenger jets, to continue to compete in the global marketplace.
Because of the U.S. aircraft industry’s innovative leadership, many airplanes manufactured by U.S. companies met the ICAO standards at the time of their adoption in 2017, and already meet the standards contained in this action. Based on the manufacturers’ expectation that the ICAO standards will be implemented globally, EPA anticipates nearly all affected airplanes to be compliant by the effective dates for new type designs and for in-production airplanes.
Under the ACE rule, when fully implemented, CO2 emissions from the U.S. power sector will be 34 percent below 2005 levels.
Massachusetts Releases Roadmap to Achieve Net Zero Emissions by 2050
Building on its ambitious commitment to achieve Net Zero greenhouse gas (GHG) emissions in the Commonwealth by 2050, the Baker-Polito Administration today released two reports - the Massachusetts 2050 Decarbonization Roadmap Report and an interim 2030 Clean Energy and Climate Plan (CECP) – that detail policies and strategies to equitably and cost-effectively reduce emissions and combat climate change. To maximize the Commonwealth’s ability to meet its 2050 target, Energy and Environmental Affairs Secretary Kathleen Theoharides set an interim 2030 statewide emissions limit of 45% below 1990 levels.
“The people of Massachusetts are experiencing record droughts, increased risk of wildfire, severe weather, and flooding in our coastal communities.  The costly impacts of climate change are on display in the Commonwealth, making it critical that we take action,” said Governor Charlie Baker. “I was proud to commit the Commonwealth to achieving Net Zero emissions, and the reports released today move the Commonwealth toward that goal equitably and affordably.”
“The release of the 2050 Roadmap and Clean Energy and Climate Plan for 2030 marks an important step forward in the Commonwealth’s strategy to reduce emissions and take meaningful action against climate change,” said Lieutenant Governor Karyn Polito. “Our ambitious Net Zero target offers us a great opportunity to build a healthier, more resilient Commonwealth, delivering significant benefits to our communities including clean, reliable energy, improved air quality, and new pathways for job creation and economic growth.”
The first-in-the-nation 2050 Roadmap outlines eight potential pathways to Net Zero emissions, including an analysis of potential energy resources, projected energy demand, and the energy supply necessary to meet the demand in all sectors of the economy while meeting the 2050 emissions limit established by the Commonwealth in April 2020. The Roadmap includes a summary report and six technical appendices, each detailing analysis and conclusions for specific sectors: Energy Supply; Transportation; Buildings; Land Use; Non-energy; and Economic and Health Impacts.
The 2050 Roadmap finds that, with careful attention to the strategies it selects, the Commonwealth can achieve Net Zero emissions by 2050 affordably while maintaining a thriving economy. Based on its analysis of a range of potential pathways, the Roadmap finds that the most cost-effective, low-risk pathways to Net Zero share core elements, including a balanced clean energy portfolio anchored by a significant offshore wind resource, more interstate transmission, widespread electrification of transportation and building heat, and reducing costs by taking action at the point of replacement for energy infrastructure.
The Roadmap also finds that achieving Net Zero emissions will deliver significant benefits to residents across the Commonwealth, including a precipitous drop in air pollution, particularly in environmental justice communities currently overburdened with poor air quality; savings in health costs of up to $100 million per year by 2030; and the creation of thousands of high-quality local jobs.
“We know that achieving Net Zero emissions by 2050 will require hard work and collaboration across all sectors of the economy in the Commonwealth,” said Energy and Environmental Affairs Secretary Kathleen Theoharides. “The 2050 Roadmap establishes a blueprint that will help us achieve our climate goals in a way that is cost-effective and delivers significant benefits to residents across the Commonwealth, especially those in our most vulnerable communities. The steps the Commonwealth takes in the next decade will help to advance the decarbonization of our buildings, transportation, and electricity sectors, and be central to meeting our 2030 emissions limit.”
The 2030 CECP will help the Commonwealth meet its 2030 emissions limit of 45% below 1990 levels, which will require a reduction in statewide emissions about 19 million metric tons below current levels.
In the electricity sector, the plan finds that the Administration’s landmark, nation-leading clean energy and clean transmission procurements including offshore wind, hydropower, and the SMART solar program will be essential to achieving the 2030 limit, while the Commonwealth will work to add an additional 2,000 Megawatts of clean energy.
The transportation sector highlights a renewed focus on the deployment of electric vehicles with new, nation-leading state and regional programs including the Transportation and Climate Initiative Program. Building on that progress, Massachusetts will join California in requiring that by 2035, 100% of new light-duty vehicles sold in the Commonwealth are zero emission vehicles (ZEVs) support the continued build-out of statewide charging infrastructure, including additional consumer incentives for residential EV charging systems.
To decarbonize the Commonwealth’s buildings sector, the report highlights the development of energy efficient solutions for homes and businesses. In order to better align Mass Save® with the state’s GHG emissions reduction targets, DOER will work with the Commonwealth’s Energy Efficiency Advisory Council (EEAC) and Mass Save® program administrators to ensure that incentives for fossil-fuel heating systems are limited during the program’s next 3-year cycle (2022-24) and all available program resources are directed to clean heating systems no later than the end of 2024. Additionally, Mass Save® will develop increased air source and ground source heat pump incentives, as well as consumer education resources. The Commonwealth will also develop a proposal for a new high-efficiency energy code for new residential and commercial buildings as an option for Massachusetts’ Green Communities, and a new Governor’s Commission and Task Force on Clean Heat.
U.S. Steel Pays $17,550 Penalty for Wetland Damage
U.S. Steel’s Keetac facility in Keewatin has paid a $17,550 civil penalty to the Minnesota Pollution Control Agency (MPCA). The company incurred the fine for its failure to prevent sediment from washing into an adjacent wetland at Keetac’s facility on multiple occasions and failure to report the incidents in a timely manner.
The uncontrolled runoff, from an earth and rock stockpile, was found deposited in a wetland down slope of the stockpile on Keetac property near the processing plant. A survey of the wetland indicated that the two incidents of unauthorized impact filled approximately 5,967 square feet of wetland.
The company paid a $17,550 penalty to the Minnesota Pollution Control Agency (MPCA) and took action to restore the damage, prevent future impacts and report releases. The Keetac facility has since submitted a Sediment and Erosion Control Plan describing activities completed and planned to control runoff from the stockpile. The facility has also committed to reporting any spills or releases in a timely manner.
MPCA permits are designed to protect human health and the environment by limiting pollution emissions and discharges from facilities. When companies do not fully comply with permit requirements, the resulting pollution can be harmful to people and the environment.
When calculating penalties, the MPCA takes into account how seriously the violations affected the environment, whether they were first-time or repeat violations, and how promptly the violations were reported to authorities. The agency also attempts to recover the economic benefit the company gained by failing to comply with environmental laws in a timely manner.
Learn How to Ship Vaccines and Other Materials in Dry Ice
When shipped by air, dry ice is classified as a dangerous good and personnel involved with its shipment must comply with stringent requirements for packaging, marking, labeling, and shipping documentation. Anyone involved in the shipment of dangerous goods must be trained on how to prepare and ship these materials by air in accordance with DOT and IATA requirements.
Attend this live interactive session and get your questions answered while you learn how to:
  • Classify and prepare shipments cooled with dry ice
  • Comply with both FAA and IATA regulations
  • Prepare shipments of dangerous goods packed with dry ice
  • Prepare shipping papers
  • Properly select, fill, and seal packages
  • Mark and label packages
  • Load, unload
  • Comply with requirements for ancillary equipment, such as trackers and temperature recorders
  • Implement essential safety and security procedures
Environmental Resource Center’s live webcast training is the best way to get certified. Learn from the experts at any of these upcoming sessions:
  • January 14 – 1:00-3:00 Eastern
  • February 22 – 1:00-3:00 Eastern
Also available is Environmental Resource Center’s online Dry Ice training that you can take anytime at your convenience.
For a complete list of other dangerous goods transportation courses, see this link.
Free Amazon HD 10 Tablet with RCRA and DOT Training
Annual training is required by 40 CFR 262.17(a)(7). Learn how to complete EPA’s new electronic hazardous waste manifest, and the more than 60 changes in EPA’s new Hazardous Waste Generator Improvements Rule. Environmental Resource Center’s Hazardous Waste Training is available via live webcasts. If you plan to also attend DOT Hazardous Materials Training, call 800-537-2372 to find out how you can get your course materials on an Amazon Fire HD 10 tablet at no extra charge.
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