If your facility is shipping quantities of hazardous materials that require placarding, including hazardous waste, you must register with the Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). The 2023 registration year begins on July 1 and runs through June 30, 2024.
Common DOT hazard classes that require registration include Class 3 (flammable) and Class 8 (corrosive). The reporting threshold is 1,001 pounds. Two 55-gallon drums are generally just under 1,000 pounds depending on the chemical(s) in them, so if your facility ships more than two drums of DOT flammable or corrosive waste in a single shipment, a registration is required.
In addition, aggregates of certain DOT classes listed in Table 2 of 49 CFR 172.504(e) also have a reporting threshold of 1,001 pounds. This includes combined Classes 3 and 8.
Some hazard classes have smaller quantities that trigger the need for registration, and other classes require registration regardless of the quantity. For instance, water reactives that ship as Class 4.3 (dangerous when wet) and Class 6.1 (poisonous by inhalation) require placarding regardless of the quantity and therefore would require registration.
In addition to quantities of hazardous materials that require placarding and therefore the need to register, the following shipments also require a registration:
- A highway route-controlled quantity of radioactive material (Class 7)
- Greater than 25 kilograms (55 pounds) of Division 1.1, 1.2 or 1.3 explosive material
- Packages containing greater than 1 liter (1.06 quarts) of material that is extremely toxic by inhalation (hazard zone A materials as specified in 49 CFR 173 )
- Any hazardous materials in bulk packaging with a capacity equal to or greater than 3,500 gallons or 468 cubic feet, even if placards are not required (such as Class 9 material)
- Shipment of 5000 pounds or more, not in bulk packaging, of one class of hazardous materials (including wastes) for which placarding is required for that class
Registration can be done by mail or online. Online registration using the PHMSA portal is the fastest way to register and is strongly encouraged. Registrations can be submitted for 1, 2, or 3 years. See the 2023-2024 Registration Brochure for more details including a table of registration fees.
Routine waste shipments as well as lab packs, especially during a lab clean out, can trigger the need for a hazardous materials registration with PHMSA. For assistance in determining whether your facility needs to register and for help navigating the registration process, please email us at firstname.lastname@example.org.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training