Department of Transportation and Shipper’s Hazardous Materials


Many companies who ship hazardous materials (which include raw materials and wastes) have let this requirement slip through a crack in their compliance program. Check this list to determine if you should be registered with the Department of Transportation as a hazardous materials (hazmat) shipper because you ship:

  • A hazmat that requires placarding (except farming operations);
  • A highway route-controlled quantity of radioactive Class 7 material;
  • Greater than 25 kilograms (55 pounds) of Class 1, Division 1.1, 1.2 or 1.3 explosive material in a freight container, motor vehicle, or rail car; A package containing greater than 1 liter of an extremely toxic by inhalation material;
  • A hazmat in a bulk package, container, or tank with a capacity equal to or greater than 13,248 liters (3,500 gallons) of a liquid or gas, or more than 13.24 cubic meters (17.3 cubic yards) of a solid.
  • A hazmat in a non-bulk package of 2,268 kilograms (5,000 pounds) or more gross weight of one class of hazmat for which placarding of a vehicle, rail car, or freight container is required.

If you meet any of the above shipping scenarios, you must register with the Department of Transportation by June 30 each year by completing Form F5800.2 and paying applicable fees, which can vary from $275. to $1,000. For more information, review the regulations governing DOT registration in 49 Code of Federal Regulations, Section 107.601 through 107.620, or call/email CTI for customer service assistance.


In May of 2007 OSHA proposed a unique and sweeping approach to updating its standards for personal protective equipment (PPE). OSHA bases this proposal upon the PPE meeting “good design standards” in lieu of periodic testing of PPE by organizations such as ANSI with subsequent rulemaking changes promulgated by OSHA. OSHA complains that the time-tested process strains its resources and slows the frequency of its rules updating. In other words, OSHA desires to replace periodic PPE updates and subsequent rulemaking changes with an ongoing, performance-based requirement that industry use PPE constructed according to standards that reflect the state of the art in terms of design safety. The net result is that as PPE is tested by ANSI or ASTM and their ratings become the standards for PPE, then OSHA’s proposal would require industry to employ that PPE without waiting for OSHA to revise its rules accordingly. The initiative behind this proposal is published at:


U.S. EPA is launching a television public service announcement, which promotes its Energy Star program as an important part of the solution to climate change. The TV spot uses ordinary people who turn to Energy Star to help save energy and money while protecting the climate for future generations. The Agency reports that in 2006, Americans using Energy Star products saved $14 billion in energy costs and prevented greenhouse emissions equivalent to those from 25 million vehicles. Savings from Energy Star are expected to double in coming years. EPA started the Energy Star program in 1992 as a voluntary market-based partnership to reduce greenhouse gas emissions through increased energy efficient products such as consumer electronics, office equipment, HVAC, and lighting. Even homes have earned the rating. See EPA’s announcement at


Highlights from a 2007 U.S. EPA Great Lakes ecosystem report:

Good News:

  • In the past 30 years there has been a marked reduction in levels of toxic chemicals in air, water, flora, fauna, and sediment;
  • The Great Lakes continue as a good source for treated drinking water;
  • In 2005, 74% of monitored beaches were open 95% of the swimming season;
  • Air quality is improving, although regions continue with ozone problems;
  • Significant natural reproduction of lake trout occurs in lakes Huron and Superior.

Bad News:

  • New chemicals of concern, including polybrominated diphenyl ethers (flame retardants) and pharmaceutical/personal care products are now being detected;
  • Fish consumption advisories continue;
  • Non-native species such as zebra mussels and spiny water fleas continue to expand and impair the food web;
  • Wetlands loss and degradation continue loss of wildlife habitat;
  • Coastal aquatic habitats are deteriorating from development, shoreline hardening, and non-native species.

Visit for the 2007 report and other related documents.


Past newsletters have related Top Ten lists for inspection shortfalls, but this issue’s list takes a lighter view of a serious topic. Our thanks to a creative individual out there in the World Wide Web!

1. EPA/OSHA sets up temporary housing in your parking lot.

2. The Inspector mutters, “This is unbelievable” each time she enters a different department.

3. EPA/OSHA calls in a professional film crew to document conditions in the plant. A reporter from “60 Minutes” tags along.

4. The Inspector insists on wearing Level A while observing your employees working in jeans and tennis shoes.

5. Your Congressman won’t return your call, but he does return your campaign contribution.

6. The Inspector begins the opening conference with, “You have the right to remain silent”.

7. The Inspector asks you a specific question about a report in your files, but you have not as yet turned over any files.

8. The Inspector knows each of your employees by their first name.

9. The Inspector is a former employee that you fired 2 years ago.

10. The Chief of the state EPA/OSHA office conducts the closing conference.


Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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