May 2020
S&R of the Sun
Just like last month, this month's newsletter includes only articles related to the COVID-19 public health emergency and the response to it by USDOT & USEPA.

In this newsletter you can read how both USEPA and USDOT have relaxed some - but not all - of their requirements due to the pandemic. Make sure you stay informed and stay compliant.

 Off-Site Transportation of COVID-19 Waste
Regulated Medical Waste
After decontamination comes disposal. But what to do with waste (PPE, filters, wipes, needles, swabs, etc.) contaminated – or potentially contaminated – with SARS-CoV-2? The answer depends on the waste's source, the state it’s generated in, and the Hazardous Materials Regulations of the USDOT .  Off-site transportation of COVID-19 Waste.
Training Options During a Public Health Emergency
Despite the COVID-19 public health emergency, USEPA, IATA, and IMO have not relaxed their training requirements. USDOT has provided relief only from recurrent triennial training but not its initial training requirement. How can you provide the required training for your employees while ensuring their safety and comfort? I have some suggestions in this short video.
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Frequently Asked Questions of EHS Managers During the COVID-19 Public Health Emergency
Can a hazardous waste generator exceed their on-site accumulation volume limit due to the COVID-19 public health emergency?

Thankfully, USEPA has offered relief from enforcement if a generator (SQG or VSQG) exceeds their on-site accumulation volume limits. Read more here.

Can a hazardous waste generator receive an extension to their on-site accumulation time limits due to the COVID-19 public health emergency?

Some hazardous waste generators (LQG & SQG) have on-site accumulation time limits for their hazardous waste. USEPA has offered relief from enforcement of these regulations during the COVID-19 public health emergency. Read more here.

Are wastes associated with COVID-19 a hazardous waste?

The answer: No. Wastes such as used medical equipment or personal protective equipment contaminated with the coronavirus are not regulated as a hazardous waste under USEPA regulations. Read more here.

How do I maintain social distancing when exchanging HazMat shipping papers?

According to USDOT it can be done if caution is exercised and the regulations are followed. Read more here.
Specification Packaging Marking
USDOT Notice of Enforcement Discretion for the Manufacturing of Packaging Designs Beyond Periodic Retesting Dates
USDOT/PHMSA is providing temporary relief from enforcement action if packaging manufacturers are unable to conduct periodic design qualification retesting within 90-days of a retest date due to COVID-19 operational disruptions

To learn more about the COVID-19 temporary retesting relief, read my article . 

USDOT Offers Relief From Regulation for Transport of Sanitizers and Disinfectants During COVID-19 Public Health Emergency
USDOT/PHMSA gives notice that it will not take enforcement action against any carrier transporting sanitizing and disinfecting materials on a motor vehicle for the purposes of protecting the health and safety of employees of the carrier provided certain criteria are met .

To learn more about the temporary enforcement action for carriers and to confirm whether you meet his criteria read my article . 
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Further Links and Information
2020 Upcoming Webinars

 USDOT HazMat Employee June 8th
USEPA Hazardous Waste (RCRA) June 22nd

USDOT HazMat Employee July 13th
USEPA Hazardous Waste (RCRA) July 20th

Register now by clicking on the date above.

Or, contact me to make arrangements for a site-specific webinar scheduled at your convenience.
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Daniels Training Services
A different kind of training
I provide training and consulting services to equip your team – whether it’s just you or a group of employees – to safely ship, receive, transport or dispose of hazardous materials and waste.