On January 25th, 2021, this Order was issued by the US Department of Transportation:
The Department of Transportation is a strong supporter of Buy American and today, we applaud President Biden for taking bold action today to ensure our future is made in America — and by American workers. The crises we face have created an opportunity to build back our economy better than before, and President Biden’s executive order will empower us to be a central force in our country’s recovery. We look forward to implementing President Biden’s Made in America executive order that will ensure transportation-related capital purchases, equipment, and supplies are acquired when available. In addition, we will also ensure that the President’s strong support of the Jones Act is realized so that only U.S.-flag vessels carry cargo between U.S. ports. With these goals in mind, the Department stands ready to help President Biden create good-paying, union jobs, and strengthen the middle class.
As this applies to the purchase of packagings bought by the DOT and other Federal agencies, we believe this will help to fuel our recovering domestic packaging industry.

https://www.transportation.gov/briefing-room/statement-us-department-transportation-president-joseph-r-bidens-made-america

Understanding the perception of the DOT will help a shipper to comply with classification, package selection, and mode of transportation. Here are 4 items from how the DOT sees it:

1. The transportation of hazardous materials exclusively on private property, to which signs, gates and guard stations prevent public access, is not subject to the Hazardous Materials Regulations.
2. If a carrier is present during the time of unloading and the motive power is still attached to the transport vehicle when an incident occurs, the carrier is responsible for submitting an incident report per CFR 171.16. If the carrier has dropped the transport vehicle and the motive power is removed from the premises, the carrier obligation is fulfilled and transportation is ended; thus, the hazardous materials incident reporting would not apply.
3. Employees subject to hazardous materials training must be tested for general awareness/familiarization, function specific and safety training in accordance with CFR 172.704. In addition, recurrent training must cover these three primary areas of knowledge. Therefore, an employee must successfully pass initial hazardous materials training in addition to recurrent training. Recurrent training cannot be waived.
4. If a hazardous material at ambient temperatures meets the definition of a solid under CFR 171.8 when packaged and offered for transportation, it is a solid material. However, if the solid will likely encounter temperatures in transportation that may cause the material to become a liquid per CFR 173.197(e)(5), then the packaging must be capable of containing the hazardous material in the liquid state.

Manufacturer’s and Reconditioners of UN certified packagings are, at all times, subject to unscheduled inspections by the Pipeline and Hazardous Materials Safety Administration (PHMSA). Recently, inspectors have stepped-up visits and therefore, it is best to be prepared if you are visited. There are 14 Checklist items that can help you to be prepared for a successful inspection. You can link to a more detailed item description HERE.

1. Make sure you, your staff and DOT inspectors wear face masks.
2. Ask the DOT inspectors for identification.
3. Ask why the Inspector is at your plant.
4. Keep Copies of all your required DOT records in one location. Inspectors are likely to ask for:
   hazmat employee training records, up-to-date annual design qualification test reports, closure instructions, and hazardous waste transportation manifests.
5. Customer information including customer invoices.
6. Make sure your employees can Answer basic training and/or operation-specific questions from the inspector.
7. Make sure you or a designated management employee accompanies the inspector during the plant tour.
8. Prepare in advance for an inspection. DOT inspectors are trained to look at the manufacturing process.
9. Create your own written record of what was observed during the inspection.
10. You may be asked to perform on-site testing.
11. Keep the exit briefing form.
12. Call Your lawyer if it appears a problem has been found.
13. Remedy the problem(s) identified by the inspector as soon as possible.
14. Respond to the exit briefing.

If prepared, the inspection should yield results that will confirm or improve your manufacturing and shipping process. For a more detailed item description of this Check-List, click HERE.