Important hazardous waste regulations are put out by the
U.S. Environmental Protection Agency, but they differ from those issued
by the U.S. Dept of Transportation or its international equivalent.
February 2018 SPRAY 25
those shipments are “in commerce.” Once sold to a personal
customer and transported in a personal vehicle, those same
hazardous materials are no longer regulated. They’re regulated
again if the person pays an airline to fly them somewhere, because
that’s a “commercial” flight (although there are some regulatory
breaks, such as for most personal care items in luggage). They’re
still regulated, however, if a business buys them, regardless of
whether paid for by “petty cash,” a company credit card or a
company charge account.
For example, a drain cleaner sold to you to use at home
wouldn’t be covered by HazMat regulations. A drain cleaner sold
to you for use at work, however, would be considered HazMat and
covered by the regulations, even if you drove it to work in your
personal vehicle.
To avoid HazMat regulations for things such aerosols, flavors
and fragrances, the answer is pretty simple: take it personally. When
you transport them yourself, for your own use, they’re not HazMat.
If you need to transport them at work or personally pay UPS or
FedEx to deliver some for you as gifts, then in those situations,
you’re not taking it personally—and you’d better comply with the
regulations. SPRAY
Gene Sanders is the owner of W.E. Train Consulting and a specialist in
regulations regarding the transportation of Dangerous Goods (sometimes
called hazardous materials in the U.S.). Sanders has degrees in Chemistry
and Biochemistry, and has several professional certifications including;
CDGT (Certified Dangerous Goods Trainer), CDGP (Certified Dangerous
Goods Professional), CET (Certified Environmental, Safety & Health
Trainer) and DGSA (Dangerous Goods Safety Advisor). Sanders is
currently the Chairman of the Board of Directors of the Dangerous Goods
Trainers Association (DGTA). If you need “five minutes of free advice”
contact Sanders at Gene@WEtrainConsulting.com or +1 (813) 855-3855.
Have a Lot of Change-Overs?
Terco’s PLC Automated Inline Equipment can solve
that issue with the press of a button. The automated
change-over process will adjust station height, rail
positions, product volume, propellant volume, servo
drive indexing speed and many other fine tuning
options in less than one minute.