PHMSA Proposes Amendments to Hazmat Regulations: Maintains Harmonization with International Standards Posted on August 28, 2014 by James Griffin

On August 25th, at 79 FR 50742, the United States Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed to amend the Hazardous Material Regulations (HMR; 49 CFR Parts 100–199) to maintain alignment with evolving international standards.

Public comments on the proposal must be received by October 24, 2014. A Final Rule is expected late this year or in early 2015, as the latest editions of the International Maritime Dangerous Goods Code (IMDG Code), International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI), and the United Nations Recommendations on the Transport of Dangerous Goods—Model Regulations (UN Model) all enter into force on January 1, 2015.

Specific issues addressed in this rulemaking docket include:

  • Incorporate Revised Standards: In addition to incorporating-by-reference (IBR) the latest international regulations, including the IMDG Code, ICAO TI, UN Model, the International Atomic Energy Agency Safety Standards, PHMSA proposes to IBR the most recent updates to the Canadian Transportation of Dangerous Goods Regulations (TDGR), and various International Standards Organization (ISO) standards.
  • Hazardous Materials Table: PHMSA proposes to add, revise, and remove entries in the Hazardous Materials Table at 49 CFR 172.101:
    • Revised names for asbestos materials;
    • New description “UN3268, SAFETY DEVICES electrically initiated, 9” inclusively replacing “air bag inflators,” “air bag modules,” and “seat belt pre-tensioners” identified by UN3268;
    • New description “UN0503, SAFETY DEVICES, pyrotechnic” replacing “air bag inflators,” “air bag modules,” and “seatbelt pretensioners” identified by UN0503;
    • Sixteen new shipping names, and associated packing provisions, for adsorbed gases; and
    • New entries for “UN3507, URANIUM HEXAFLUORIDE, RADIOACTIVE MATERIAL, EXCEPTED PACKAGE” and “UN3508 CAPACITOR, ASYMETRIC.”
  • Provide Exceptions for Marine Pollutants: PHMSA proposes to exclude from regulation packages that contain small amounts of materials that are only marine pollutants when packed up to 5 L (1.3 gallons) or 5 kg (11 lbs.) per package. This matches existing provisions of the IMDG Code.
  • Modify the Marine Pollutant List: PHMSA periodically updates the list of regulated marine pollutants in Appendix B to 49 CFR 172.101, based on changes to the IMDG Code.
  • Clarify Various Hazard Communication Requirements: PHMSA proposes to add minimum size requirements for OVERPACK and SALVAGE markings. This matches recently adopted amendments prescribing minimum size requirements for identification number markings. Furthermore, PHMSA makes subtle amendments to the specifications for labels and placards. All these rules have a transitional period until December 31, 2016.
  • Revised Vessel Stowage Requirements: PHMSA proposes to update vessel stowage codes in Column 10B of the HMT and other provisions regarding vessel stowage, consistent with the most recent edition of the IMDG Code.
  • Additional Entries for Adsorbed Gases: To keep pace with evolving international standards, PHMSA proposes to include seventeen new entries for “adsorbed gases” in the HMT and to make other necessary amendments for these materials (i.e., definitions, authorized packagings, safety requirements).
  • Harmonized Requirements for Lithium Batteries: PHMSA proposes to incorporate provisions for lithium batteries equivalent to Section IB of ICAO Packing Instructions 965 and 968 for large amounts of small batteries and to modify the provisions for communicating the prohibition of lithium metal batteries from passenger aircraft.
  • Expanded Definition of Non-Bulk Packaging: International authorities have recognized packagings suitable for the transport of high-volume, low-mass materials (such as air bags). PHMSA proposes to revise the definition of non-bulk packaging to include certain large single packagings that meet UN specifications.

The 18th Revised Edition of the UN Model enters into force on January 1, 2015 and includes many other changes that PHMSA is not considering. Harmonization issues NOT under consideration include:

  • Damaged, Defective, and Waste Lithium Batteries: The HMR adopted provisions for these lithium batteries in a previous rulemaking.
  • Dimensions on Hazard Communication Examples: PHMSA is not adding reminders of the dimensions to the existing images of hazmat placards and labels, as the minimum dimensions are already provided in the text of the HMR.
  • Flash Composition: PHMSA is not adopting the UN Model’s new criteria for the “flash composition” of a firework, because work on the HSL Flash Composition test is ongoing.
  • Radioactive Materials: The most recent UN Model and IAEA Standards include many changes for transporting radioactive materials. PHMSA is prohibited from incorporating most of them without coordination with the Nuclear Regulatory Commission. Further domestic harmonization will be addressed in a future joint rulemaking.
  • Discarded Packages: PHMSA is not adopting the new international shipping description “UN3509, PACKAGING DISCARDED, EMPTY, UNCLEANED” as existing provisions in the HMR already adequately address the shipment of empty uncleaned packagings.
  • Used Medical Devices: PHMSA is not adopting the 2015 ICAO TI’s new exception for used medical devices. Existing provisions of the HMR satisfactorily address the hazards presented by used medical devices.
  • Coolants, Conditioners, and Asphyxiates: The 18th Edition of the UN Model will make various editorial amendments to the provisions for packages and cargo transport units containing asphyxiates used for cooling/conditioning. As PHMSA did not adopt these regulations when they were included in the 17th Edition of the UN Model, the Agency won’t’ adopt these amendments either.
  • Gas Cartridge and Fuel Cell Testing: As the HMR already adequately address the hazards of these items, PHMSA won’t adopt the alternatives authorized in the 18th Edition of the UN Model.

LDR Paperwork for RCRA “Prohibited Wastes” Posted on August 26, 2014 by Roseanne Bottone

What Is Prohibited Waste?

A prohibited waste is one that, if it were disposed of, would be subject to land disposal restrictions (LDRs) in 40 CFR Part 268. Examples of prohibited wastes include:


  • Hazardous wastes as defined at 40 CFR 261.3;
  • Hazardous secondary materials excluded from the definition of solid waste at 40 CFR 261.4(a);
  • Hazardous secondary materials that are solid wastes but are excluded from the definition of, or from regulation as, hazardous waste at 40 CFR 261.4(b)-(f);
  • Hazardous wastes that are recycled according to 40 CFR 261.6; and
  • Hazardous wastes that leave RCRA jurisdiction subsequent to generation (e.g., wastes that are reclaimed or introduced into a Clean Water Act permitted wastewater treatment unit).

The LDRs specify recordkeeping requirements to account for prohibited wastes.


Providing Information to the TSDF

The “Notification” or “Land Ban Form”

When a hazardous waste does not meet the LDR treatment standards, the generator must ensure the waste is treated before disposal.
A generator prepares a notification for the treatment, storage, and disposal facility (TSDF) that contains information as specified at 40 CFR 268.7(a)(2), so the TSDF knows how to treat the hazardous waste prior to disposal. Generators often call this notification a “Land Ban Form.”

The “Certification”

If the hazardous waste already meets the treatment standard at the original point of generation, or if the generator treats the waste on site to meet LDR standards, then the generator must prepare a certification that includes the information specified at 40 CFR 268.7(a)(3). A statement must be included in which the generator certifies that, through analysis and testing or through knowledge of the waste, the waste complies with LDR treatment standards.


Special Rules for Excluded and Exempted Wastes

The “One-time Notice to File”

Under RCRA, some wastes are excluded from the definition of solid or hazardous waste or are excluded from regulation as hazardous waste. While the wastes are excluded from the RCRA management rules, the generator must still account for this waste under the Land Disposal Restrictions. To accomplish this, the generator prepares a form known as the “One-time Notice to File” to keep on record at the facility.

Examples of prohibited wastes excluded from the definition of solid or hazardous waste include:


  • Unlisted sludges and by-products that exhibit a characteristic of hazardous waste that are reclaimed;
  • Commercial chemical products listed at 40 CFR 261.33 or that exhibit a characteristic that are reclaimed;
  • Spent sulfuric acid reclaimed and meeting the conditions of 40 CFR 261.4(a)(7); and
  • Used oil filters that are hot drained and meet the conditions of 40 CFR 261.4(b)(13).

The contents of the “One-time Notice to File” are specified at 40 CFR 268.7(a)(7). The generator must describe the disposition of the waste and how it was generated and excluded from the definition of solid or hazardous waste. While this notice must be kept in the generator’s files and be available for inspection, the generator is not required to send it to the EPA or State regulatory agencies (unless specifically required by State regulation).

Wastes Exempted from RCRA After Generation

The same one-time notice is required for hazardous waste exempted from hazardous waste regulation subsequent to (i.e., after) its generation and must include a description of how the exemption occurred. Some examples of wastes exempted from RCRA after generation include:


  • Spent solvents that are reclaimed (e.g., spent acetone that is distilled) to recover a usable component (40 CFR 261.3(c)(2)(i));
  • Recyclable materials from which precious metals are reclaimed (40 CFR 261.6(a)(2)(iii)); and
  • Wastes that are de-characterized in a Clean Water Act permitted wastewater treatment unit and discharged through sewer systems to a publically owned treatment works (POTW) or as point source discharges (40 CFR 261.4(a)(1) and (2)).

Understanding the LDR requirements is a crucial element of effective hazardous waste management. Overlooking these rules or failing to properly document your waste for treatment and disposal can lead to redundant treatment costs, US EPA fines as high as $37,500 per day/per violation, and future liability under CERCLA.

Be confident your hazardous waste operations are in compliance with the latest RCRA rules, including the complex Land Disposal Restrictions, with expert RCRA training. Lion’s Hazardous/Toxic Waste Management Workshop, online course, and refresher online course are all designed to satisfy the EPA’s annual training requirement for hazardous waste personnel at 40 CFR 262.34(a) and 265.16.

Significant Changes to IATA’s 56th Edition DGR Posted on August 21, 2014 by Roger Marks

Significant Changes to IATA’s 56th Edition DGR

This fall, the International Air Transport Association (IATA) will publish the 56th Edition of its Dangerous Goods Regulations. Compliance with the 56th edition DGR is mandatory starting January 1, 2015. To help shippers stay up-to-date with the latest hazmat air shipping rules, below is a summary of major changes that will appear in IATA’s forthcoming edition:

“Hidden Dangerous Goods” – GHS Labels on Packages

Under paragraph 2.2.2, IATA added a note that alerts package handlers that diamond-shaped hazard communication pictograms-required under the Globally Harmonized System for Classifying and Labeling Chemicals (GHS)-may indicate that a package contains hazardous materials/dangerous goods. The note will help freight forwarders, ground handling agents, and operators identify hazardous shipments.

Updates to the List of Dangerous Goods (IATA 4.2)

The 56th edition DGR will include a number of new and revised entries on IATA’s List of Dangerous Goods, including:


  • Adding 17 new entries for absorbed gases (UN 3510-3526), including nine general, N.O.S. entries.
  • Removing the packing group from all articles that had been assigned a packing group, including lithium batteries.
  • Deleting the Proper Shipping Names “air bag inflators,” “air bag modules,” and “seat belt pretensioners” (UN 0503 and UN 3268) and replacing them with “Safety devices, pyrotechnic” (UN 0503) and “Safety devices electrically initiated” (UN 3268).
  • Amending the entry for Lithium metal batteries (UN 3090) to show “forbidden” across Columns I/J. UN3090 shipments are now restricted to Cargo Aircraft Only. This change does not affect UN 3091, lithium metal batteries packed with (or contained in) equipment.
  • Changing the Proper Shipping Names for “blue,” “brown,” and “white” asbestos (UN 2212 and UN 2590).

Changes to IATA Special Provisions

IATA is making changes to a number of commonly used special provisions. These include:


  • Assigning a new Special Provision A192 for materials such as Paint/Paint related material and Printing ink/Printing related material. The new SP allows shippers to use only the “related material” Proper Shipping Name on the Shipper’s Declaration when the standard entry substances and the “related material” entry substances are in the same package.
  • Assigning new Special Provision A201 for Lithium metal batteries (UN 3090) to identify that these batteries may be carried on passenger aircraft subject to specific size and quantity limits.

Changes to IATA Classification Criteria

IATA is also making a number of changes to the classification and naming criteria for hazmat air shipments, including:


  • Adding a statement to clarify that packing groups for materials and specific packaging performance level requirements are addressed in the applicable Packing Instruction (PI). (3.0.3.3)
  • A reference for the conditions that apply to absorbed gases. (3.2.1.2)

Revised Packing Instructions for Lithium Batteries (Section 5)

IATA is revising a number of packing instructions, including those for lithium batteries. For a complete list of revised instructions, view the full IATA document here.


  • Clarifying PI 966 and PI 969 for lithium ion and lithium metal batteries packed with equipment.
  • Updating PI 968 for Lithium metal batteries to identify them as for transport on Cargo Aircraft only.

Hazmat Marks and Labels (Section 7)


  • For the 56th edition DGR, IATA clarifies the size and dimensions for all hazard and handling labels.
  • Mandatory as of January 1, 2016, a new provision has been added which mandates a minimum size for lettering of the OVERPACK marking. (7.1.7)

Dangerous Goods Documentation [Section 8]


  • Clarifying and updating the documentation requirements, including those for viscous flammable liquids (8.1.6.11.6) and lithium batteries prepared under Section IB of PI 965 and 968.
  • Adding a new paragraph, 8.2.6.2, recommending shippers identify “not restricted” on the air way bill for non-DG packages bearing diamond-shaped GHS hazard communication labels.

The full document from IATA lists many other changes that will affect hazmat air shippers in 2015. Click here to read the full summary of significant changes from IATA.

56th Edition Now Available for Pre-Order

Hazmat air shippers can now pre-order the 56th edition IATA DGR at Lion.com. Shippers who order their copies before October 1 will receive free shipping to anywhere in the US. DGR pre-orders will begin shipping on November 1. Pre order your copy today to make sure your team has access to the rules they must follow in 2015 as soon as possible—don’t wait!

New Proposals in Hazmat Regulation Posted on August 21, 2014 by James Griffin

Reverse Logistics

On August 11, at 79 FR 46748, the Department of Transportation Pipeline and Hazardous Material Safety Administration (DOT PHMSA) proposed to revise the Hazardous Material Regulations applicable to return shipments of certain hazardous materials by motor vehicle.

Hazmat “reverse logistics”—how retailers, manufacturers, and distributors deal with product returns of hazardous materials—is a pressing issue in hazmat safety. When a customer returns an item that contains or is itself hazmat, personnel otherwise unfamiliar with the Hazardous Materials Regulations may be tasked with preparing the shipment for transport.

Specifically, DOT PHMSA proposes to:


  • Define the term “reverse logistics” as the process of returning goods to or between a vendor, distributor, manufacturer, or other person for the purpose of returning for credit, recalling product, replacement, or similar reason (for instance, from a retail or wholesale outlet).
  • Establish a new section 49 CFR 173.157 to provide an exception for materials that are transported in a manner that meets the definition of ”reverse logistics.” In this exception, PHMSA proposes to clearly identify 1) the hazardous materials authorized, 2) packaging, 3) hazard communication, and 4) training requirements applicable to reverse logistics shipments.
  • Expand the existing exception at 49 CFR 173.159 for reverse logistics shipments of used automobile batteries that are being shipped from a retail facility to a recycling center.

This notice of proposed rulemaking follows an advanced notice and request for information published on July 5, 2012 (77 FR 39662). PHMSA will be receiving public comments on this proposal until October 10, 2014, under Docket Number PHMSA-2011-0143(HM-253).

Standard Operating Procedures for Evaluating Special Permits and Approvals

On August 12, at 79 FR 47047, the Department of Transportation Pipeline and Hazardous Material Safety Administration (DOT PHMSA) proposed to address certain matters identified in the Moving Ahead for Progress in the 21st Century Act (MAP-21) related to the Office of Hazardous Materials Safety’s Approvals and Permits Division.

Specifically, DOT PHMSA proposes to incorporate its established special permit and approva policies into a new Appendix A to 49 CFR Part 107, including:


  • Clear criteria for the technical completeness of applications;
  • Standard operating procedures for evaluating whether special permits and approvals provide an equivalent level of safety;
  • Standard operating procedures and criteria for evaluating the “fitness” of applicants to fulfill their obligations; and
  • Revised definitions for the terms special permit and approval:
    • Special Permit means a document issued by the Associate Administrator, the Associate Administrator’s designee, or as otherwise prescribed in the HMR, under the authority of 49 U.S.C. 5117 permitting a person to perform a function that is not otherwise permitted under the Hazardous Material Regulations.
    • Approval means a written authorization, including a competent authority approval, issued by the Associate Administrator, the Associate Administrator’s designee, or as otherwise prescribed in the HMR, to perform a function for which prior authorization by the Associate Administrator is required under the Hazardous Material Regulations.

This proposal is another step in a multi-year program to standardize and streamline PHMSA’s special permit and approval program. PHMSA will be receiving public comments on this proposal until October 14, 2014, under Docket Number PHMSA-2012-493(HM-233E).

Hazmat Shipper Training

Be confident that you’re prepared for compliance with the latest hazmat shipping regulations for ground (US DOT), air (IATA), and ocean (IMO). Lion’s Multimodal Hazmat Shipper Certification Workshops are presented nationwide by expert instructors. Sign up today and gain peace of mind that you’re ready for any compliance challenge.

How Small Is Too Small for Hazmat Markings? Posted on August 19, 2014 by Robert Clarke

In 2013, domestic and international regulatory agencies (DOT, IATA, and IMO) implemented regulations to standardize the size of markings on packages of hazmat. Standardization across national borders, modes of transportation, and industry sectors streamlines compliance, reduces confusion, and increases the safety, security, and efficiency of international hazmat transportation. During this process, the one element that was not standardized was the implementation date.

US Hazardous Material Regulations

Markings on Non-bulk Packages: To harmonize domestic rules with international standards, starting January 1, 2017, the United States Department of Transportation will enforce minimum size requirements for identification number markings on non-bulk packages. This requirement does not apply to other markings on the package, such as the Proper Shipping Name and shipper’s or receiver’s name and address. The new size requirements for identification number markings are:


  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages greater than 5 and up to 30 kg or L
  • At least 6 mm in size for cylinders less than or equal to 60 L water equivalent
  • Of an adequate size for smaller packages

Until January 1, 2017, the minimum size for markings is optional. Also, packages that are permanently marked, by embossing or otherwise, before 2017 can remain in use without meeting the size requirements until the end of their useful service life.
[49 CFR 172.301(a)(1)]


IATA’s Dangerous Goods Regulations (IATA DGR)

Marking Size on all Packagings: Effective January 1, 2014, the IATA DGR instituted minimum size requirements for markings on packagings. The identification number markings must be:


  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages greater than 5 and up to 30 kg or L
  • Of an adequate size for smaller packages

For overpack and other package markings, such as the Proper Shipping Name and the shipper’s and consignee’s name and address, the minimum sizes are:


  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages less than or equal to 30 kg or L

[IATA DGR 7.1.4.4]

IMO’s Dangerous Goods Code (IMDG Code)

Marking Size on all Packagings: Effective January 1, 2014, the IMDG Code instituted minimum size requirements for identification number markings on packagings. This requirement does not apply to other markings on the package, such as the Proper Shipping Name and the shipper’s or receiver’s name and address. The identification number markings must be:


  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages greater than 5 and up to 30 kg or L
  • At least 6 mm in size for cylinders less than or equal to 60 L water equivalent
  • Of an adequate size for smaller packages

Cylinders with a capacity of less than or equal to 60 liters that were marked prior to January 1, 2014 can continue to be used until the next or periodic inspection but must be in compliance with the 6 mm minimum size requirement by July 1, 2018 at the latest.
[IMDG 5.2.1.1]

If you are not currently operating according to the above regulations, it is advisable to make the required changes to your operations. Abiding by the rules is important for several reasons:


  • DOT inspectors can come to your company at any time to ensure compliance-
  • Fines for hazmat shipping violations are now as high as $75,00 per day, per violation.
  • Easily visible markings aid the efficient processing of your packages by carriers.
  • Markings provide important information to first responders in the event of an incident in transit.
  • Avoid costly processing delays.
  • Maximize customer satisfaction.

Be confident your team has the knowledge and skills to prepare your hazmat shipments for ground, air, and ocean transport at the Multimodal Hazmat Shipper Workshops, presented nationwide. These interactive, engaging workshops cover the latest domestic and international hazmat shipping regulations and are designed to satisfy the applicable training standards for hazmat employees.

State EPCRA Variations Posted on August 12, 2014 by Anthony R. Cardno

The United States is a big nation with citizens who experience life differently in each state. Different food, different geography, and different music are only part of what makes the US an exciting place to live and work. That said, EHS managers know that there is another important difference between states, one that can cause confusion in industry: the environmental regulations.

The US EPA authorizes State agencies to adjust or add to the Federal air, water, and chemical regulations in order to better ensure compliance in their state. One environmental law that many states have “customized” is the Emergency Planning and Community Right-to-Know Act (EPCRA).

Section 312 of EPCRA requires the US EPA to collect annual data from facilities that have hazardous chemicals on site above certain threshold amounts at any one time.

Those thresholds, established in 40 CFR 370, are:


  • ≥10,000 lbs. for any “hazardous chemical” as defined in 29 CFR 1910.1200; or
  • ≥500 lbs. or the threshold planning quantity, whichever is lower, for “extremely hazardous substances” listed in 40 CFR 355.


This data is collected via the Tier I or Tier II reports submitted to the facility’s Local Emergency Planning Committee (LEPC), State Emergency Response Commission (SERC), and nearest fire department on or before March 1 each year. The Federal regulation allows the reporter to choose which form to submit (the Tier I requires less detailed information than the Tier II), unless the SERC, LEPC, or fire department requires the Tier II.

While the US EPA gives facilities a choice of which form to submit, most states require submission of the more detailed Tier II report. This is just one example of the many variations different states use to implement EPCRA.


Fees and Additional Information

Twenty-four states assess a fee for filing the report, the dollar amount of which varies from state to state. Some states require interim updates (Oregon and Pennsylvania among them) or allow alternative calculation methods for certain industries (Louisiana). In Oregon, the reporting deadline varies from county to county.

Extra Chemicals and Lower Thresholds

Nevada, Oregon, Alaska, New Jersey, Missouri, and California all have expanded lists of chemicals that must be reported under EPCRA. Nevada, Oregon, Delaware, Louisiana, Vermont and California also have lower reporting thresholds for some, if not all, of the chemicals.

Case Study – California Business Plans

California’s Business Plan program is an excellent example of a State program subsuming the Federal one. Since 1986, facilities in California have been required to comply with the Business Plan program if they handle hazardous material (including hazardous wastes, hazardous substances, etc.), including:


  • Liquids in amounts greater than or equal to 55 gallons; or
  • Solids in amounts greater than or equal to 500 lbs.; or
  • Compressed gases in amounts greater than or equal to 200 cubic feet; or
  • Extremely hazardous substances listed in 40 CFR 355 in amounts greater than or equal to that substance’s threshold planning quantity.

Facilities subject to the Business Plan requirements must submit information electronically to the California Environmental Reporting System
(CERS), where it will be verified and evaluated by the facility’s Certified Unified Program Agency (CUPA). The required information includes:


  • An inventory of the site’s hazardous materials;
  • A detailed site map;
  • A detailed emergency plan; and
  • A training program for employees.

The CUPA then passes this information on to the LEPCs, SERCs, local fire departments, and more.

Gain an understanding of the Federal Tier II reporting requirements by attending the Complete Environmental Regulations Workshop. The workshop covers the critical elements of major EPA air, water, and chemical programs. You will get up to speed on new and changing regulations, know what permits and plans your site needs, and build confidence to make the right EHS decisions for your company.

PHMSA’s New Lithium Battery Rulemaking Published Today Posted on August 06, 2014 by Roger Marks

Today’s Federal Register includes a new US DOT Final Rule that makes major changes to the requirements for shipping lithium batteries in or from the US. The Final Rule incorporates international standards into the US DOT’s Hazardous Materials Regulations. These new lithium battery shipping regulations are effective immediately, and shippers have until February 6, 2015 to ensure their shipments are in compliance with the new requirements.

Among the major changes introduced by this rulemaking are:

  • New classification criteria for lithium ion cells and batteries
  • New marking and labeling requirements for lithium battery shipments;
  • New requirements for transporting lithium batteries for disposal or recycling
  • New provisions for shipping and transporting damaged, defective, and recalled lithium batteries
  • Separate shipping descriptions for lithium metal and lithium ion batteries
  • Revised provisions for shipping “small” and “medium” cells and batteries

The US DOT requires all hazmat shipping employees to complete training once every three years and as rules change that affect their responsibilities. [49 CFR 172.704] For the first time, US DOT lithium battery shipping regulations will now be harmonized with international standards such as the International Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO), as well as the UN Model Regulations.

To help lithium battery shippers prepare for compliance with the new DOT requirements, Lion Technology will present the Shipping Lithium Batteries Webinar in August and September. The live, instructor-led webinar covers the latest regulations for shipping lithium ion or metal batteries by ground, air, and ocean. The webinar now covers the new requirements in PHMSA’s final rule and how they will immediately affect US shippers.

The webinar will be presented from 1 to 3 PM ET on August 12. Additional sessions will follow on September 11, September 23, and October 21. The cost for the webinar is $229 per student, and group discounts are available. Registration includes access to the interactive webinar, a copy of the presentation, a newly updated Compliance Reference, and a review quiz. Shippers can register online or by calling 888-546-6511.

When Lifting Objects, Do It Right Posted on August 05, 2014 by Joel Gregier

For many US employees, work involves tough manual labor, and one of the most common requirements is to lift heavy objects. Lifting objects is an everyday requirement of jobs in industries from manufacturing and construction to retail. Because heavy lifting is such an ordinary activity, workers may not take safety precautions seriously. Workers should be aware that lifting objects incorrectly can lead to serious injuries and problems and that they should have the information and equipment to protect themselves in the workplace.


Back Injury Frequencies

The US Department of Labor (DOL) collects information on workplace injuries and makes that data available to the public. According to its most recent statistics, back injuries, or “overexertion,” are the most common injuries. More than 20% of injuries that require days away from work or restricted or transferred duties (DART) are caused by overexertion in lifting or lowering.

Causes of Overexertion

According to the Bureau of Labor Statistics, over 50% of all DART injuries are soft-tissue damage (sprains, strains, tears, soreness, and bruises). Common causes of soft-tissue injuries include lifting objects that are too heavy, are too bulky, or have their weight unevenly distributed. During the lifting process, employees may bend, twist, or turn their bodies in ways that result in injury. It is critical to train employees on proper lifting techniques to prevent these types of injuries.

Preventing Back Injuries

Under its General Duty Clause, the Occupational Safety and Health Administration (OSHA) requires employers to protect their employees from preventable injuries, whether or not the injury is addressed by a specific OSHA standard. While OSHA has not issued a formal standard for lifting technique, overexertion is a preventable condition and therefore subject to the General Duty Clause.

With that said, there are common safety precautions that employees can take to prevent injuries while lifting. For instance, when moving materials manually, employees should:


  • Attach handles or holders to loads (if possible),
  • Wear appropriate personal protective equipment, and
  • Use proper lifting techniques.

Proper Lifting Technique


One of the easiest ways to prevent back injuries is to follow proper lifting techniques. Again, while this is not specifically outlined by OSHA, the following technique is a good rule of thumb to follow:


  • Step 1: Plan ahead before lifting.
  • Step 2: Set feet shoulder width apart.
  • Step 3: Bend your knees and keep your back straight.
  • Step 4: Grip the load firmly.
  • Step 5: Tighten your stomach muscles.
  • Step 6: Lift with your legs.
  • Step 7: Keep your back straight as you lift.
  • Step 8: Lift close to your body.
  • Step 9: If you’re straining, get help.

Protect Your Team With Expert Training

While supervision and a strong safety program help keep workers safe, employees must be prepared to take steps to protect themselves and their co-workers from injury and illness in the workplace. Expert OSHA training at Lion.com is available to satisfy a number of OSHA training standards, as well as provide awareness training on a variety of workplace hazards.

US Postal Service Revises Standards for Hazardous Material Posted on July 29, 2014 by James Griffin

On July 24, 2014, the United States Postal Service, in Postal Bulletin 22394, declared its intention to revise the Domestic Mail Manual (DMM) as part of an initiative to eliminate redundancy and streamline information. For lithium battery shippers, this revision is especially important: Under Section 662.52 of the DMM, the allowance for mailing laptops and other portable electronics powered by lithium-ion batteries through airmail has been restored.

Hazmat shippers should note that Part 601 of the DMM Mailability, which covers hazardous, restricted, and perishable mail, has been heavily revised. New section 601.8 provides a high-level overview of hazardous, restricted, and perishable mail. For detailed instructions, USPS guides mailers to Publication 52 “Hazardous, Restricted, and Perishable Mail.”

Publication 52 was itself revised effective May 15, 2015 in Postal Bulletin 22389.

Hazardous mail is discussed in Chapter 3 of Publication 52. Section 332 summarizes the USPS’s standards on mailing hazardous material to “generally limit the mailing of hazardous materials to ORM-D (permitted for surface transportation only until January 1, 2021), and consumer commodity or mailable limited quantity materials as defined in Sections 332-336 that meet USPS quantity limitations and packaging requirements.”

The revised Chapter 3 of Publication 52 now incorporates the US DOT’s elimination of the ORM-D classification and streamlined provisions for consignments of hazmat packed in limited quantity.

This revision also restores one allowance that stirred some controversy last year. Per Section 662.52 of Publication 52, individuals can again send laptops and other portable electronic equipment powered by lithium-ion batteries through airmail and to overseas APOs, as long as they conform to applicable standards of the post office and 49 CFR.

DOT and OSHA Criteria for Biohazards Posted on July 29, 2014 by James Griffin

DOT and OSHA Criteria for Biohazards

Infectious substances and pathogens are regulated by both the US DOT and OSHA due to the unique hazards they pose, namely causing disease in humans or animals. The DOT and OSHA regulations vary in scope because the two programs have different goals: the former seeks to ensure the safety of hazmat transported on public roads, while the latter protects employees from these hazards in the workplace.

Infectious Substances as DOT Hazmat

The US DOT regulates infectious substances in its Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) along with explosives, poisons, and other dangerous chemicals. Materials known (or reasonably expected) to contain a “pathogen” are classified as Division 6.2 Infectious substances. Pathogens are microorganisms or other agents that can cause disease. Among the materials that may contain pathogens are human tissue or body fluids, soiled linens and medical waste, and bacterial cultures. These materials are considered hazmat under US DOT rules and should be prepared for transport accordingly.


Shipping Division 6.2 Infectious Substances

The US DOT separates Division 6.2 Infectious substances into two categories: A and B. Category A materials are capable of causing permanent disability or life-threatening or fatal disease. Category B materials, while still hazardous, are not expected to cause disability or sickness as severe as Category A materials.

For more information about shipping Division 6.2 materials, see Lion’s July 15 article, Hazmat in Healthcare.


Bloodborne Pathogens Safety

With respect to biohazards, OSHA’s goal is to protect the health and safety of workers at hospitals, doctor’s offices, clinics, and other workplaces where employees may be exposed to blood or other potentially infectious materials. These workplaces must comply with OSHA’s Bloodborne Pathogens Standard at 29 CFR 1910.1030. The Standard lays out expansive definitions of “exposure” and “other potentially infectious material.” In essence, any physical contact with blood or other human body fluid or tissue is assumed to be exposure to infectious material.

OSHA’s Bloodborne Pathogens Standard includes requirements to control workers’ exposure to these materials: a written plan, engineering controls, work practices, personal protective equipment (PPE), rules for designated sharps containers, hazard communication, recordkeeping, and more.

Intersection of DOT and OSHA Rules

When it comes to packaging and shipping biohazards, the DOT and OSHA regulations intersect. One popular option for containing biohazards in the workplace is to use a biohazard “red box.”

Hazmat shipments packaged in the red box and affixed with the correct OSHA label are exempted from many of the US DOT’s Hazardous Materials Regulations (49 CFR 173.134).

49 CFR Shipper Training for Medical Hazmat and Waste

For hazmat shippers in the medical industry, Lion offers online training for both Shipping Infectious Substances and Shipping Regulated Medical Waste. Learn the US DOT regulations for classifying, naming, packaging, marking, labeling, loading, unloading, and documenting these hazmat shipments. The US DOT requires training for all hazmat employees once every three years, and fines for hazmat shipping mistakes are now as high as $75,000 per day, per violation.

For employee training on OSHA’s Bloodborne Pathogens Standard, Lion also offers the Bloodborne Pathogens Online Course.

EPA Discusses Rag Rule Posted on July 22, 2014 by James Griffin

On July 31, 2013, the US EPA promulgated a new final rule to relax hazardous waste management requirements for solvent-contaminated wipes (i.e., shop towels). Under this rulemaking, solvent-contaminated wipes that are laundered are conditionally excluded from regulation as solid waste, and discarded solvent-contaminated wipes are conditionally excluded from regulation as hazardous waste.

The EPA recently held a webinar to discuss the relatively new Solvent-Contaminated Wipes Rule. The webinar was hosted by Amanda Kohler and Mary Beth Sheridan of the US EPA and attended by dozens of State regulators, industry groups, regulated businesses, and other stakeholders. During the webinar, the hosts discussed the background of the solvent-contaminated wipe waste stream and the history of this rulemaking, and then answered questions from stakeholders.


Background of Solvent-contaminated Wipes

Until the final rule was published, there was no official EPA system for managing solvent-contaminated wipes and rags. They aren’t quite covered by either the contained-in policy or the mixture rule (40 CFR 261.3(a)(2)(iv)).

In 1994 (RO11813), the US EPA made it its official policy to defer the identification of solvent-contaminated wipes as hazardous waste to EPA Regions and the states. In 2003, the US EPA proposed Federal regulations (68 FR 65586) to create a uniform national standard for managing these wipes as special wastes under Subtitle C of the Resource Conservation and Recovery Act (RCRA). The 2013 final rule created this national standard, offering conditional exclusions from RCRA for certain solvent-contaminated wipes.

The rule is currently in effect in Alaska, Iowa, and in Indian Country and other territories where the US EPA directly implements RCRA. Some authorized states, namely Pennsylvania, New Jersey, Virginia, North Carolina, Illinois, and Florida, have also adopted the rule. See this map from the US EPA.

The EPA intends to update its Frequently Asked Questions for solvent-contaminated wipe soon.

Key Takeaways from the EPA’s Webinar


  • The exclusion is conditional and includes explicit instructions for managing and disposing or recycling shop towels. If handlers violate one or more of the conditions of the exclusion, the wipes become subject to RCRA regulation from their point of generation.
  • The storage and containment rules are flexible and performance-based; they do not specify a type or material for storage containers. There is no quantity limit, only a 180-day time limit for accumulating solvent-contaminated wipes.
  • Reusable wipes can be laundered on site, provided the on-site laundry discharges under a Clean Water Act permit or agreement.
  • Mats, mops, uniforms, and other personal protective equipment cannot be managed under the solvent-contaminated wipe rule, because the EPA did not consider them under the scope of the rule.
  • Handlers may not add absorbents to containers accumulating solvent-contaminated wipes.
  • When wipes are co-contaminated with oil and solvents, they may be managed under the solvent-contaminated wipe rule as long as (1) the oil is not listed hazardous waste and (2) the wipes only exhibit the characteristic of ignitability (and thus do not exhibit the characteristic of corrosivity, toxicity, or reactivity).

For more information, click here for the solvent-contaminated wipes rule.

Projected Effect and Cost Savings

According to the US EPA, if this rule is implemented nationally, it will impact:


  • Over 90,000 facilities generating solvent-contaminated wipes, most of them small quantity generators;
  • Over 3,000 solid waste management landfills and combustors; and
  • Over 300 industrial laundries and dry cleaners.

The US EPA estimates about $18 million in net waste management savings and 4 to 10 million in peripheral benefits if this rule is adopted and implemented nationwide.

Be confident your site is in compliance with the latest RCRA hazardous waste regulations, including the new rules for shop towels and developing standards for electronic Manifests! For annual training on the EPA’s core requirements for managing and storing hazardous waste on site, Lion presents the Hazardous/Toxic Waste Management Workshop in cities nationwide. An online course and Refresher online course are also available.

Seeking new management strategies or recycling options to minimize waste and cut costs? The Advanced Hazardous Waste Management Workshop also covers the RCRA rules that generators must know, with an emphasis on strategies to streamline your operations, to keep waste “out of the system” of RCRA, and to treat waste on site without a RCRA permit.

Hazmat in Healthcare: Division 6.2 and Medical Waste Posted on July 15, 2014 by Ross Kellogg

Hazardous materials shippers have many responsibilities under US DOT regulations. The first and arguably most important step of the hazmat shipping process is classifying the material.

If this first step is done incorrectly, the packaging selected for the shipment may not be compatible or strong enough; the marks, labels, and shipping papers will be inaccurate; etc. In the event of an incident in transit, emergency responders will not have the information required to make the best judgment about how to react and respond. The classification requirement is found at 49 CFR 173.22.

With many materials, classification is a relatively simple process. Some hazmat, though, can be rather complicated to classify and may even require special expertise in a specific related field. One example of this is the classification of Division 6.2 infectious substances.


What Is a DOT “Infectious Substance”?

The US DOT defines an infectious substance as “a material known or reasonably expected to contain a pathogen.” [49 CFR 173.134] Pathogen is further defined as a microorganism (e.g., bacteria, viruses, parasites, fungi) or other agent, such as an infectious particle, that can cause disease in humans or animals. Examples are the Ebola virus and hoof-and-mouth disease and the cultures taken from them. Not all these pathogens are regulated the same way, if at all, and Division 6.2 is further divided into two categories:


  • Category A: An infectious substance in a form capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs.
  • Category B: An infectious substance that is not in a form generally capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs.

An exposure occurs when an infectious substance is released outside of its protective packaging, resulting in physical contact with humans or animals.

Exceptions to the Division 6.2 Shipping Rules

As with many hazmat shipping regulations, there are a number of exceptions that apply to specific materials. Here is a brief list:


  • A material that does not contain an infectious substance or that is unlikely to cause disease in humans or animals
  • A material containing micro-organisms that are non-pathogenic to humans or animals
  • Blood, blood plasma, and blood components for blood transfusion or of blood products and sent for testing, if believed not to contain a Category A or Category B infectious substance
  • Certain laundry and medical equipment and used healthcare products
  • Agricultural products and food as defined in the Federal Food, Drug, and Cosmetics Act

Having a medical background certainly could be helpful to make the distinction between a Category A and Category B substance. Following are some general guidelines and examples.

Category A vs. Category B Infectious Substances

A Category A infectious substance that is potentially fatal must be assigned to identification number UN 2814 or UN 2900, as appropriate. Assignment to UN 2814 or UN 2900 must be based on the known medical history, symptoms, or professional judgment concerning the source. UN 2814 is assigned to materials that can affect humans and UN 2900 to those that only affect animals. A blood sample from a patient know to have the Ebola virus, for example, would be assigned UN 2814, while one containing hoof-and-mouth disease would be UN 2900.

A Category B infectious substance must be described as “Biological substance, Category B” and assigned identification number UN 3373. This does not include regulated medical waste, which must be assigned identification number UN 3291. An example of a Category B substance is a tissue sample containing Hepatitis B.

Shipping Regulated Medical Waste

The rules for shipping regulated medical waste, UN 3291, differ from the infectious substance regulations. Sometimes known as clinical waste or (bio) medical waste, regulated medical waste is a waste or reusable material derived from the medical treatment of an animal or human or from biomedical research.

When packaged to the specific standards at 49 CFR 173.134(c)(2), some Category B infectious substances meet the definition of regulated medical waste. For example, Category B waste cultures transported as regulated medical waste conforming to certain packaging and transportation requirements can get relief from the majority of the regulations. Medical waste containing a Category A infectious substance, however, must be classed as an infectious substance and assigned to UN 2814 or UN 2900, as appropriate.

While medical-related hazmat makes up only a small portion of US hazmat shipments each year, the dangers posed by these materials are very real. By ensuring their materials are classified and named correctly, hazmat employees in the healthcare industry can be confident their shipments are safe in transit and that emergency response personnel have the best information possible to respond in the case of an emergency.

49 CFR Shipper Training for Medical Hazmat and Waste

For hazmat shippers in the medical industry, Lion offers online training for both Shipping Infectious Substances and Shipping Regulated Medical Waste. Learn the US DOT regulations for classifying, naming, packaging, marking, labeling, loading, unloading, and documenting these hazmat shipments. The US DOT requires training for all hazmat employees once every three years, and fines for hazmat shipping mistakes are now as high as $75,000 per day, per violation.

Updating Your EPA Risk Management Plan Posted on July 08, 2014 by Anthony R. Cardno

Under the Clean Air Act, owners or operators of facilities at which a process uses “…more than a threshold quantity of a regulated substance…” [40 CFR 68.10] must create a Risk Management Plan (RMP) to prevent the accidental release of these substances to the ambient air and to minimize the consequences of releases that do happen.

Because both EPA regulations and industry best practices change over time, EHS managers must ensure their facility’s RMP is maintained and updated when necessary. At 40 CFR Part 68, the EPA sets specific standards for revising and updating Risk Management Plans under specific circumstances.


Elements of a Risk Management Plan


  • The substances regulated under the RMP rules are listed at 40 CFR 68.130, Tables 1 through 4.
  • A process is defined as “any activity involving a regulated substance including any use, storage, manufacturing, handling or on-site movement of such substances, or combination of these activities … [including] any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could be involved in a potential release….” [40 CFR 68.3]

At a minimum, RMPs must be fully updated and resubmitted at least every five years. [40 CFR 68.190(b)(1)] These revised plans must be submitted via the same RMP*eSubmit software used for initial submission of RMPs. Visit the EPA’s website for more information on electronic Risk Management Plan submission.

Updating RMPs Due to Change in Quantity

Under certain circumstances, RMPs must be updated and resubmitted before the five-year anniversary:


  • If a new regulated substance, above the appropriate threshold, is added to an existing process.
  • If an existing regulated substance is increased to above the appropriate threshold for the first time.

In both of these cases, the facility must update and resubmit the RMP by the time the regulated substance is present in a process at a quantity that is greater than the regulatory threshold.

Updating RMPs Due to Revised Analysis

Facilities must also update RMPs within six months of any change that requires:


  • A revised process hazard analysis or hazard review [40 CFR 68.190(b)(5)],
  • A revised off-site consequence analysis [40 CFR 68.190(b)(6)], or
  • A change in applicable program level [40 CFR 68.190(b)(7)].

Updating RMPs Following Emergencies or Accidents

Facilities must also revise their RMPs in relation to releases and emergency preparedness.


  • Accidental releases that meet certain criteria must be:
    • Added to “five-year history” and “incident investigation” sections of the RMP
    • Within six months of the date of the accident.

  • Changes to facility emergency contact information must be:
    • Corrected in the RMP within one month of the change.
    • Revisions to other RMP sections not required.

Deregistration from the RMP Reporting Program

Facilities that make changes that drop them out of the RMP requirements (for instance, removing processes or limiting the amount of the hazardous substance to stay below the threshold quantity) must submit a de-registration to EPA within six months of the change. [40 CFR 68.190(c)] Maintaining an up-to-date and accurate Risk Management Plan not only ensures compliance with 40 CFR 68, it also helps facilities comply with the more broadly applicable General Duty Clause of the Clean Air Act [CAA Section 112(r)(1)] and emergency preparedness requirements under other major EPA programs.

Build EHS Expertise and Confidence

Build confidence that you’re up to date with the latest water, air, and chemical programs that affect your facility. Knowing your legal obligations under the EPA’s major regulations is critical—missing even one environmental mandate can lead to costly fines and penalties, releases, and future liability. The hands-on Complete Environmental Regulations Workshop is designed for both new and experienced EHS professionals. Through expert instruction, collaboration with other EHS professionals, and real-world exercises, you will understand how these complex sets of laws and regulations apply to your facility—and how to make the right decisions for your business.

Preventing Heat Illness in the Summer Posted on June 30, 2014 by Joel Gregier

OSHA Administrator David Michaels recently renewed his Agency’s commitment to protecting employees from high-heat hazards—which can cause serious physical harm and even death. “This is a common-sense thing,” said Michaels, who urged employers to ensure they provide workers with sufficient water, rest, and shade. Last year, OSHA issued 11 citations for heat-related violations, including $33,000 in fines for a refuse removal company whose employee died working a 10-hour shift on a garbage truck in 99 degree heat.

Now that summer is underway and the heat index has broken 90 degrees in many places, it is more important than ever for employers to protect workers from the dangers of excess heat. While there is no specific OSHA standard regulating high temperatures, companies must protect their employees from heat illnesses. [OSHA Act Sec.5]

OSHA realizes the importance of heat protection during warm months. In fact, in 2011, OSHA created the “Campaign to Prevent Heat Illness in Outdoor Workers” to specifically address the hazards posed by extreme or prolonged exposure to heat.


What Risks Are Involved With Working in the Heat?

When overheating, the human body naturally tries to cool itself through sweating. In extreme heat, however, the body can no longer regulate itself properly if no preventative measures are taken.

Common illnesses include heat rash, heat cramps, heat exhaustion, and heat stroke. Heat stroke is particularly dangerous in that it can lead to death if not immediately treated.

How Can You Prevent Heat Illnesses?

Thousands of workers are affected by heat illnesses every year. The sad fact is that nearly all of these incidents are preventable.

Among other things, the following methods can help prevent heat illness:



  • Provide workers with water. OSHA has suggested that workers drink water every 15 minutes, even if they are not thirsty. It may be too late to hydrate once the body has used up all its water.
  • Provide rest and shade. Bodies need time to cool down throughout the day. Sitting down under a tree or, even better, getting time in an air-conditioned space can make all the difference.
  • Allow workers to acclimatize to the heat. Statistics have shown that new workers and those workers who have taken more than a week off are the most susceptible to heat illness. This is because the body needs time to build tolerance to the heat. To help with this, these workers should have a work schedule that allows them time to acclimatize.
  • Modify work schedules, if needed. Even the strongest workers can still be taken aback when a heat wave hits. In these cases, maybe a shorter workday or more frequent breaks are needed. In some cases, workers can maybe spend part of the day working indoors.
  • Plan for emergencies and train employees on symptoms and prevention. Workers should be able to notice when they or coworkers are having difficulties. Knowing common symptoms, such as flushed faces or light-headedness, can possibly catch a problem before it becomes serious.
  • Monitor workers for illnesses. Employers also need to take a proactive role and watch their workers’ actions. Even if an employee is in the midst of something like heat exhaustion, recognizing this hazard early is much better than letting it escalate to heat stroke.
  • Possibly provide personal protective equipment (PPE). Employers are not required to supply “ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.” [29 CFR 1910.132(h)] However, providing these or other types of PPE can help employees during warm weather.

More information about OSHA’s “Campaign to Prevent Heat Illness in Outdoor Workers” can be found on OSHA’s website.

24/7 Online OSHA Training at Lion.com

For convenient training that covers many OSHA standards, Lion Technology offers 24/7 online courses at www.Lion.com/OSHA-Training. Lion.com online courses save workers’ progress throughout, so they can start and stop as needed to fit their work schedules. IT support for online training is available 7 days a week.

RCRA Workshop Helps Manufacturers With “Zero Landfill” Initiatives Posted on June 25, 2014 by Roger Marks

At manufacturing and industrial facilities nationwide, managing hazardous waste can be a burdensome and expensive responsibility. Compliance professionals must manage their waste to exacting standards and pay to have the waste hauled away, treated, and disposed of safely. In addition to these management, treatment, and disposal rules, the Resource Conservation and Recovery Act (RCRA) requires annual training for facility personnel at hazardous waste generator sites.

The high cost of proper hazardous waste disposal and the threat of future liability for improper disposal and environmental contamination have driven many facilities to work toward minimizing the volume of hazardous waste generated on site. As more companies move toward these “zero landfill” initiatives, streamlining hazardous waste operations becomes critical to gaining and maintaining a competitive advantage.

To help experienced EHS managers discover new management strategies to minimize waste and lower waste treatment and disposal costs, Lion Technology will present the Advanced Hazardous Waste Management Workshop in area cities in July and August. In addition to meeting the US EPA’s annual training mandate under RCRA, this unique workshop emphasizes cost-cutting options such as:

  • Capitalizing on waste ID and counting exclusions
  • Keeping solid waste “out of the system” of RCRA
  • Treating waste without a RCRA permit
  • Best practices for waste minimization and pollution control
  • Managing used oil and universal waste, and more

The workshop will be presented in Kansas City on July 14-15, St. Louis on July 17-18, Chicago on July 21-22, Detroit on July 24-25, Cincinnati on August 4-5, and Pittsburgh on August 7-8. Enrollment includes annotated 40 CFR RCRA regulations, a searchable Reference CD, a how-to reference workbook, a pocket-sized quick reference guide, and 365 days of updates and compliance support. The cost for the two-day workshops is $895/student. Group pricing is available.

More information on the workshop, presented nationwide, is available at Lion.com/ZeroLandfill.