+ DOT Shipping Primer Dwight Clark, CHMM Full Circle Compliance, LLC

+ Topics What are DOT Hazardous Materials Where can I find them in e-scrap How are they regulated What are the best practices

+ What is a DOT Hazardous Material? It can be nearly anything, either product or waste The level of environmental regulation does not matter The formal definition in regulation is “A substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has been designated as hazardous under section 5103 of the Federal hazardous materials transportation law (49 U.S.C. 5103).”

+ DOT Hazardous Material The term includes: Hazardous Substances Hazardous Wastes Marine Pollutants Elevated Temperature Materials Materials designated as hazardous in the Hazardous Materials Table (see 49 CFR ), and Materials that meet the defining criteria for hazard classes and divisions in part 173 of subchapter C of this chapter

+ Typical e-scrap processor DOT Hazardous Materials Batteries All chemistries including (but not limited to): Lithium Primary – button cells, some household batteries (AA, C, D) Lithium Secondary – Laptop, cellphone, tablet, headphones, etc… Lead Acid Sealed – toys, emergency lights, small UPS Wet - Large equipment, large UPS NiCd – tools, forklifts Mercury – button cells Silver - button cells

+ More typical e-scrap processor DOT Hazardous Materials Includes all forms of Batteries: Installed in or packed with equipment Shipped separately Shipped for recycling Shipped for disposal Universal Wastes as discussed in Corey’s presentation: Lamps, Mercury Containing Devices Flammable Liquids CRT Fines by ocean transport in some cases (as a marine pollutant) Polychlorinated Biphynels (yes, the other PCBs) in light ballasts and older electrical equipment

+ How are they regulated? In all 50 States the shipments are regulated under the US Department of Transportation in 49 CFR sections The shipper’s responsibility is best characterized by the rule in 49 CFR “Each person who offers or who performs a pre- transportation function for a hazardous materials shipment must do so only in compliance with Subchapter C of the Hazardous Materials Regulations” By air implemented by use of the International Air Transport Association (IATA) Dangerous Goods Regulations By International Maritime Dangerous Goods (IMDG) regulations.

+ Inspections / Enforcement Inspections in the US: Conducted by enforcement agencies, including: DOT – all three regulations; FAA for IATA; US Coast Guard for IMDG; State Highway Patrol for DOT Civil Penalties: Violations of any hazardous materials regulations, including training, may be subject to a civil penalty of up to $50,000 for each violation.

+ Best Practices Invest in Training for some staff to monitor for Hazardous Materials in shipping If you ship lithium batteries in any case you have some requirements for this either way Review materials coming in and going out for possible hazardous materials and review identification and classification requirements. Develop a solid Hazardous Materials Shipping SOP Remember you are the shipper and have the responsibility even if someone completes the paperwork for you

+ Generalized Hazardous Materials Shipping Process Identification Classification Proper Shipping Name / Description Packaging Marking Labeling Placarding Segregation Shipping Papers Emergency Response Information

+ Final Thoughts The DOT published changes to shipment of Batteries in August which go into effect around the new year. Several e-scrap companies have been visited by DOT / FAA for shipments by ground and air based on the current hype over lithium batteries.

+ For more information Dwight Clark, CHMM Full Circle Compliance LLC Cell: