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:
- 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.
- 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.
- 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.
- 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.