DOT HAZARDOUS MATERIAL TRANSPORTATION (HAZMAT)

The Hazardous Materials Transportation Act of 1975 was passed to “protect the Nation adequately against risks to life and property which are inherent in the transportation of hazardous materials in commerce.” The federal regulations in 49 CFR 100-180 are under Department of Transportation jurisdiction and detail HAZMAT requirements. It is a rare logger that does not transport hazardous materials at one time or another. This LCO is NOT intended to be used to implement a HAZMAT program in your operation, but to provide a brief explanation of the requirements and to help you determine how they apply to your operation.

1. What is a hazardous material? The simplest answer is that its what the DOT says it is. The DOT maintains a HAZMAT Table that designates what they consider to be hazardous. Things on this list that loggers transport include gasoline, acetylene, all pressurized cylinders (even when empty), and batteries (because they contain sulfuric acid).
2. Where does HAZMAT apply? HAZMAT regulations apply ONLY when you are on the public highway system. HAZMAT is frequently confused with OSHA Hazard Communication Standard (HAZCOM). HAZCOM also applies when you are at the worksite. (See LCO-3)
3. What are the requirements? Loggers carrying hazardous materials must train their employees, prepare and carry Shipping Papers and emergency response information, and properly label or placard their shipments. The word “Shipping” is misleading, as HAZMAT applies even when you are “shipping” from home to the job, or between jobs.
4. What is a shipping paper? Shipping papers must follow a specific format and contain information such as what the substance is, amount, specific hazard codes, where it is coming from and going to, and how it is packaged. Shipping papers must be kept on or within reach of the driver’s seat.
5. What Is “Emergency Response Information”? The simplest way to comply with this requirement is to have a copy of the “Emergency Response Guidebook,” developed under the supervision of the DOT, in each transporting vehicle. This pocketbook is inexpensive, available from commercial sources of safety materials, and provides all emergency information required for every substance listed in the HAZMAT Table.
6. What training is required? HAZMAT training is required every three years on regulatory requirements and safety issues, and must include a test. The employer must certify that all his employees who load, move, or prepare paperwork have been trained.
7. Are there any exceptions? Yes. Two specific regulations provide a lot of relief from HAZMAT requirements if carefully followed:
     • “Combustibles,” including diesel fuel and oil, are exempt from HAZMAT regulation as
        long as they are carried in approved containers 119 gallons or less. (Gasoline is
        considered a “Flammable.”)
     • Materials of Trade — Although a full definition or explanation will not fit in this LCO,
        these include most hazardous materials you might carry that are used for safety, for
        vehicle maintenance, or on-the-job. There must be no more than 440 pounds total,
        and they must be transported in approved containers no greater than 8 gallons for
        liquids and 66 pounds for solids.
8. Where do I get more information? Call your local DOT office, or go to the government HAZMAT web site at http://hazmat.dot.gov.

Prepared by the Southwide Safety Committee, Forest Resources Association Inc.