GROUNDED

Most air travelers do not feel comfortable until they get to the airport and in their seats. It’s the same with the Department of Transportation (DOT) and the International Air Transport Association (IATA), dangerous goods air shipments. The toughest part is getting your air shipment from your loading dock to the airport, not onto the plane.

IATA  is a group of companies, airline companies. It’s a boys’ club. You can be in the club, but you gotta play by their rules.  

The International Civil Aviation Organization(ICAO) and The United Nations(UN) on the other hand, are two separate groups of international governmental aviation representatives. They come from countries around the world that work together to standardize dangerous goods requirements.

IATA does not require Safety and Security Training or In-depth Security Plans.

VS

DOT requires Security Awareness Training and In-depth Safety and Security Plans.

According to DOT, Dangerous Goods transferred solely inside the bounds of an airport, in most cases, would only be required to meet the International Air Cargo Organization(ICAO) Recommendations and the United Nations Dangerous Goods Recommendations(DGR), which are the framework of IATA air requirements.

 Getting to and from the airport is the problem. The highway portion, that’s when DOT ground regulations overlap with ICAO air shipping requirements. That’s when the Pipeline and Hazardous Materials Safety Administration(PHMSA) becomes the Pilot In Command(PIC).

IATA only authorizes Intermediate Bulk Containers(IBC) for UN3077, Environmentally Hazardous Substance, Solid N.O.S., 9, PG III when following Packaging Instruction 956.

DOT authorizes Intermediate Bulk Containers(IBC) for both UN3082 and UN3077 Environmentally Hazardous Substance, Liquid and Solid N.O.S., 9, PG III in Section 173.241.

 The Department of Transportation Subpart C, The Hazardous Material Regulations, Section 171.23, covers international shipments and use of UN and ICAO recommendations by air, when going to and from the airport and the port area. This contains a list of these DOT regulations that are not in the ICAO or International Maritime Organization(IMO) Recommendations.  

The Department of Transportation does not recognize IATA requirements as it is an association of airlines, unlike ICAO and the IMO.  This is all moot, if you just remember that the ICAO Dangerous Goods Recommendations are used as the framework of the IATA air requirements.

 ICAO outlines where to list constituent chemicals on the shipper's declaration, whereas, DOT tells you what and when to list. For example, the names of the top two reportable quantities, marine pollutants, or shipping names displaying a letter “G” in column number one of the 172.101 Hazardous Materials Table. 

IATA  Requires Training Every Two Years

DOT Requires Training Every Three Years

 Unless a dangerous goods course provided copies of and covered all of the relevant 49 CFR hazardous material regulations, it would be unreasonable to assume that it would meet the DOT 172.700 training, testing, documentation and certification regulations.

If you need training to meet DOT ground regulations and IATA air cargo rules, sign up for our DOT/EPA/OSHA Compliance Seminar and then the IATA Air Add-On Seminar, both at a date and time of your choosing. It’s the best way to keep both DOT and the airlines happy.

Robert J. Keegan,
Publisher and President
Hazardous Materials Publishing Co.
Transportation Skills Programs Inc.
www.hazmat-tsp.com
Text to 610-587-3978 
Hazmat.tsp@gmail.com

George, the ocean called!

It was sad to hear that some breaded shrimp,  the frozen ones, might be contaminated with Cesium-137 radioactive isotopes. Before I go any further, the contaminated shrimp are safe to eat. As long as you don't eat too many. “George!”

What could have caused this contamination? Were the shrimp harvested from an area exposed to radioactive fallout from Cold War atomic bomb testing? Possibly harvested by mistake or knowingly, by unscrupulous villain type characters?

 If the shrimp were processed overseas, could they have been exposed to contaminated shrimp meal, polluted or contaminated water?  

 One of our local beekeepers would ship his empty hive boxes and frames at the end of the season to be irradiated, to kill germs and parasites. He explained it was also used by food processors for the same reasons. So, maybe faulty, improperly calibrated equipment or cross contamination mistakes could have occurred.

Then what about containers and other packaging that might have been “reused" after shipping or storing radioactive hazardous materials or waste?

So, I called up Lisa at the office and asked her what she thought, and Lisa said, she thought that, I thought too much”

But, did inform me, per these recent events, she read that there has been some discussion of re-authorization and expansion of the The Radioactive Compensation Act which provided support for individuals exposed to radioactive fallout. 

Then assured me that when updating our Free Federal Register Update Service she would make sure The Department of Transportation, (DOT), The Environmental Protection Agency, (EPA) or The Occupational Safety and Health Administration, (OSHA) wasn't proposing any new radioactive transportation, environmental or worker protection requirements without letting everyone know.

 I can't wait to see the New 2025/2026 Hazardous Materials, Substances & Wastes Compliance Guide, which is on its way from the printers, so don't wait, order now or get yours sent to you when you register for the 2025/2026 Hazardous Material, Substance and Waste Compliance Seminar. Immediately upon completion of the seminar you will receive your DOT/EPA/OSHA Training Certifications.

Thank you for your support. Reach out if you have any questions or concerns.

2025/2026 Hazardous Materials, Substances and Wastes Compliance Guide

from $125.00

Price per Quantity:

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Robert J. Keegan
Publisher and President
Hazardous Material Publishing Company
Transportation Skills Programs
Hazmat-tsp@gmail.com
Text 610-578-3987

IT’S ABOUT LIABILITY NOT SAFETY

The hazardous materials incident happened at the San Francisco port area offices of Wells, Fargo and Co. after a crate had arrived from New York by way of Panama two days earlier. Upon its arrival, a 300 pound, two and half by two and half foot crate was found to be leaking an oily and unfamiliar substance. Per policy, it was taken to their offices to assess liability for the freight, upon the ensuing attempts to open the crate its contents of nitroglycerin exploded, causing massive destruction and death.

Shortly thereafter, the SS European, a steam ship transferring cargo for its pre-Canal Panama Railway Company portion of the trip to California, blew apart in Aspinwall, Panama, killing over 50 people. Later it turned out to be falsely identified as “Glorian Oil”, a fictitious substance. These two incidents lead to a dramatic drop in sea going passenger travel as newspapers and the public speculated on a similar explosion at sea. In addition, there were financial concerns that large shipments from the California Gold Rush might be lost.

In the ensuing legal battles, the 1866 United States Supreme Court clarified that as the Carrier of Record, Wells, Fargo and Co. was deemed non-liable. The shipper was required to identify and package a material properly regardless of its contents. 

 Class and Describe: 
 Shippers must classify and describe hazardous materials under 49 CFR.

Authorized Packaging: 
Shippers must ensure that the packaging is authorized 
and complies with the relevant specifications.

 Closure Instructions: 
Shippers are required to precisely follow the manufacturer's closure instructions.

Use specified packaging components:                             
 Adhere to torque specifications for containers.
 Apply the correct type and amount of tape.
Ensure proper assembly and sealing of the package.

Maintain
 Manufacture closure instructions for 90 days.

 It’s been over 100 years since the first hazardous material regulations were written, targeting primarily rail and water, then in later years embracing highway and air.

It’s the shipper and generator that do the heavy lifting. The improper selection and closure of containers opens your company to corporate and even personal liability. Don’t become part of history, make sure your employees are properly trained and have the most up-to-date regulations at their disposal.

2025/2026 Hazardous Materials, Substances and Wastes Compliance Guide

from $125.00

Price per Quantity:

Select Price per Quantity 1-5 Books ( $140 Per Book) 6-10 Books ( $135 per Book) 11-24 Books ( $130 per Book) 25-50 Books ( $125 per Book)

Purchase

Robert J. Keegan
Publisher and President
Hazardous Material Publishing Company
Transportation Skills Programs
Hazmat-tsp@gmail.com
Text 610-578-3987

KEEP YOUR PANTS ON!

Look out, your sunscreen could contain harmful chemicals.

              Avobenzone, Homosalate and Oxybenzone are used for their dermal penetration properties but may pose unknown risks.  FDA safe, however, in some studies they have been shown to be harmful to aquatic life, in addition to causing rare hormone disruptions and allergies to the skin.  

Makes me think of the Occupational Safety and Health 1910.120(q) Hazardous Material 24 Hour Hazmat Team Response Training. Physical activity on even a cool day in a fully encapsulated protective suit can bring on dehydration, disorientation, heat stroke and death, in addition to unforeseen circumstances and physical malfunctions to gloves, suits and respirators. 

The most important aspect of the OSHA training was to understand that personal protective equipment may pose more of a danger than chemical hazards. Especially, taking into account that in many cases hazmat team responders will ultimately determine there was no health hazard present based on the material, exposure limits and its chemical hazards. 

 That is why first and foremost, the responsibility of hazmat Specialists in 1910.120(q)(6)(iv)  is to support and protect their Technicians under 1910.120(q)(6)(iii). Ever ready to immediately suit up into a higher level of protection, as they would assume rescue team status in the event of emergencies.      

The late John Sabatino, my instructor and good friend, would say “Anyone with a pulse can climb into a fully encapsulating suit, but he’s never seen anyone climb out without one”.

Some conscientious hard-core sun worshipers have gone the route of topical sunscreens  containing Titanium Dioxide or non-nano Zinc oxide, a Department of Transportation (DOT) hazardous material which doesn't penetrate the skin, however may according to studies pose inhalation hazards. 

There is one more option. My dad’s form of sunscreen, regardless of the season, activity or temperature was a cotton t-shirt, 100% polyester V-neck sweater, leather aviator jacket, battered Levi’s, a pair of Bausch and Lomb aviator sunglasses and one of my grandfather’s Eagles football caps.

Two more seminars this year, and I’m out for the summer, see you in October. Thank you!

Be Safe,
You’ve made it this far. 

Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc.
hazmat.tsp@gmail.com
610-587-3978

I don't know?

WHAT’S GOING ON ? 

The 40 CFR Environmental Protection Agency (EPA) Hazardous Waste e-Manifest website regulations are not a road or a path you follow, they are more like a quilt. Small pieces and patches of requirements from different sections of regulations that must be stitched together.

 Sew, with the help of Luke (a longtime client), Jeff (a contemporary), Bryan (EPA), Linda (a longtime client), then Luke along with Jennifer at the Pennsylvania Department of Natural Resources (PADNR), and the material in the Federal Register Reprint Service, here’s what Lisa helped me put together.

Visit Frequently ask questions about e-manifest.

Register, as all large and small quantity generators must be registered with RCRAInfo. This will enable generators to access and maintain final hazardous waste Treatment Storage Disposal Facility, (TSDF) manifest acceptance copies online.

Visit: Reporting and Fee Collection Division and RCRAInfo for registration instructions.

Continue using the current five form paper or online manifests and mailed reports until December 1, 2025, even after the new e-manifest system, with its four form manifests and its new online Exceptions, Discrepancies, Unmanifested Waste and Export Reports is up and running.

Read the Final Rule

Start using, upon approval, either the new four form paper or online hazardous waste manifest, and the online filing of the Exceptions, Discrepancies, Unmanifested Waste and Export Reports into the e-manifest system. You can also continue using the current five form paper or online hazardous waste manifest, until December 1, 2025 at your discretion.

Open The EPA E- Manifest Website

 Stop, using the current five form hazardous waste paper form and online manifests on December 1, 2025, then begin submission of the paper or online four form hazardous waste manifest. In addition the paper Exceptions, Discrepancies, Unmanifested Waste and Export Reports will no longer be accepted by mail.

FREE DOT EPA OSHA Federal Register Reprint Service

Print, or provide a paper copy of the EPA hazardous waste manifest, to the transporter’s driver, for use as the 49 CFR Department of Transportation, (DOT) hazardous material shipping paper regardless of which manifest is used.

 Luke, after IATA Dangerous Goods training, was the first to ask me “What’s going on with the manifest?” I said, "I don't know, What’s going on with the manifest ?” So Lisa, upon being informed of my ignorance, immediately gathered the new e-manifesting requirements from her federal register updates and sent them off to Luke.

Bryan at EPA, was next (helpful, friendly and forthcoming), he was listed as the contact in the Federal Register. He helped me to better understand evolving procedures and the timelines for the new four form e-manifest’s approval. Linda, a close and nearby client, furnished us with a few more pieces or patches with her e-manifest experiences and anticipated e-manifest system concerns.

Luke and Jennifer at PDNR from start to finish furnished their insights and offered to answer written questions if needed.

  It seams, sometime before December 1, 2025,  EPA will be removing Form 3 or the “Designated Facility Copy” from the waste manifest and begin accepting online Exceptions, Discrepancies, Unmanifested Waste and Export Reports as the reports will no longer be accepted by mail after that date. 

However, generators may continue to use the online and paper O.G. 5 form manifest, until December 01, 2025 or the online or paper four form manifest once approved. 

My wife Erin is an accomplished quilter. Me, I’m more of a blanket guy, as in “Pigs in a Blanket”. If you have any questions, concerns or comments, please reach out, 

Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs
hazmat.tsp@gmail.com 
Text me at 610-587-3978