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Office of Security, Safety and Risk Management

Department of Transportation Hazardous Materials Regulation

The Transportation Uniform Safety Act became law in 1990. It defined Federal vs. state authority, introduced required training for hazmat employees, and required a 24 hour emergency response number. It became known as Hazardous Material Regulation 181 (HM-181).This 10 year phase-in plan is intended to better regulate the transport of hazardous materials and to bring U.S. regulations on packaging and transportation of hazardous materials in line with the United Nations Standards used extensively throughout the world.

The regulation of transportation of hazardous materials has been going on for a long time. In 1866, the federal government regulated the transport of nitroglycerine for obvious reasons. In 1966 The Department of Transportation (DOT)was established and assumed the responsibility of regulating hazardous materials from the Bureau of Explosives. In 1974 the Transportation Safety Act authorized the DOT to enforce hazardous materials regulations for all modes of domestic transportation.

HM-181 affects all persons involved with hazardous materials in commerce. Basically, if you transport any quantity of a hazardous material over a public highways, (or streets), you are governed by these regulations.

The transitions dates and regulations are:

1. October 1, 1991 - Items identified as poisonous by inhalation must include the words "POISON-INHALATION HAZARD" or "INHALATION HAZARD" on the shipping papers in association with the proper shipping name.
2. October 1, 1992 - Items identified as poisonous by inhalations are subject to the new communication requirements, including placarding
3. October 1, 1993 - Performance packaging requirements for all items identified as poisonous by inhalation are in affect. New requirements for segregation during transportation are in effect. All hazardous materials offered for transportation are subject to the new classification and communication requirements.
4. January 1, 1994 - Items identified as infectious substances, (included regulated medical waste), are subject to all applicable requirements including classification, communications, and packaging.
5. October 1, 1994 - Packaging manufactured on or after this date must comply with performance packaging standards. All packaging must now be tested and certified and may be subject to vibration, leakproffness, pressure, drop and stacking test. Each packaging used to transport hazardous materials must be designed and constructed and have its contents so limited that under conditions normally incident to transportation, there will be no release of the contents to the environment and the packaging integrity will not be compromised. The packaging must be compatible with their contents. New regulations for placarding are effective.
6. October 1, 1996 - All shipment of hazardous materials must meet new performance packaging requirements.
7. October 1, 2001 - Placard format and content must comply with new specification requirements.

Another important aspect of HM-181 is employee training. Employers must ensure that each hazmat employee (any person who in the course of employment directly effects hazardous materials transportation safety) is trained and tested about hazardous material safety. The training should include general awareness which should provide familiarization with the requirements of the regulations as well as recognize and identify hazardous materials. Function specific training on matters specifically applicable to the functions the employee performs. And safety training should include emergency response information, accident avoidance, and safe handling of hazardous materials. HM-181 requires the hazmat employee to receive this training at least once every two years.

How is Denison University affected by HM-181? First, employees who use public roads to transport hazardous materials must comply with all requirements includingsafety training. Second, if anyone wants to ship a hazardous material, the container must be constructed to meet performance packaging standards and have appropriate labels and identification numbers on the container. After October 1, 1996, all container must not have been previously used. The reasoning behind this is many people do not take the time to remove IDs and labels that may not be applicable to the new contents. Third, it you do want to ship a hazardous material, you will be required to supply a 24 hour emergency response number with a person able to give details as to appropriate clean up and exposure hazards. Therefore, these regulations will make shipping hazardous materials much more difficult. However, if the quantity is small, (less than 25 grams), then the shipment is exempt from HM-181 regulations. If you have a larger quantity then consider breaking it down into small quantities to avoid having to meet the requirements of HM-181

For more information, contact Mary Lindsey.
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Last modified: Thursday December 20, 2007 14:23:00