From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

Nov. 30, 2008

Have you checked you hazardous waste transporter's license lately?

It is a good idea to periodically check to see if your hazardous waste transporter is still licensed. Our licensed transporter web site keeps a list of licensed hazardous waste transporters and has recently been updated to provide even more information. Now you can click on a transporter's EPA identification number and find out information such as contact, phone number, and what wastes the company can transport.

July 30 2008


See notes highlighted below:

Feb. 28, 2008

Gross vs. Net Weight When Shipping Hazardous Substances:

Deciding whether to use the gross weight (substance plus packaging) of a shipment or the net contents weight (substance only) of a shipment may be tricky. The bottom line is this, the U.S. Department of Transportation does not specifically require that you use net or gross weight therefore either is acceptable  however, the Uniform Hazardous Waste Manifest instructions state that you should “To the extent practical, report quantities using appropriate units of measure that will allow you to report quantities with precision. Waste quantities entered should be based on actual measurements or reasonably accurate estimates of actual quantities shipped. Container capacities are not acceptable as estimates.” When shipping hazardous substances it may be more effective and less confusing to use net weight (substance only) on the manifest, especially if the substance's weight is below but close to the reportable quantity (R.Q.). Reportable quantity is the quantity of a substance, per single package, specified in the U.S. Department of Transportation regulations that triggers special labeling, packaging, and other requirements related to shipping the substance. By using net weight you can avoid adding the weight of the associated packaging that may make your shipment appear to be over the R.Q. Let's go over an example of when using net weight might be best for your shipment and how to "show your work" to an inspector.

Example: You are shipping five separate packages, each containing 6 ounces of Beryllium Nitrate. The reportable quantity for Beryllium Nitrate is 1 pound. You decide to use packaging that weighs 2 pounds, therefore your gross weight is over 2 pounds. You do not mark R.Q. on the shipping paper because according to 49 CFR 171.8 a hazardous substance is defined as a quantity "in one package" and in this example you only have 6 ounces in each package. A truck inspection is performed at your business or you are stopped roadside while transporting the waste. A review of your manifest shows that you have over 2 pounds of Beryllium Nitrate in each package and you have not marked it on the manifest as an R.Q. This would appear to be a violation of U.S. Department of Transportation regulations. To prevent any misunderstanding, you may list the hazardous materials on item 9b of your Uniform Hazardous Waste Manifest in one of three ways:


  • 5 packages each containing 6-oz of material can be written as:5 boxes, 30 oz., UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII, (6 oz. per box), or
  • 5 boxes, 6 oz. per box, UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII, (30 oz. in total), or,
  • list it five separate times
    • 1 box, 6 oz, UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII
    • 1 box, 6 oz, UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII
    • 1 box, 6 oz, UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII
    • 1 box, 6 oz, UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII
    • 1 box, 6 oz, UN2464, Waste, Beryllium Nitrate, 5.1, (6.1), PGII

On October 1, 2007, a new regulation became effective that requires the numbers and types of packages to be shown on the shipping papers; see 49 CFR 172.202(a)(7). Because of this new rule, it may be more time effective for some businesses to record gross weight (substance plus packaging) on the new uniform manifest, however, when transporting hazardous waste you must follow the hazardous waste manifest instructions and make your decision based on these. If your company does want to use gross weight in their hazardous waste transportation practices, you can note in the special handling/additional information field the net weight of each hazardous substance. This simple note may eliminate confusion during roadside or hazardous waste transporter facility inspections. Click here to see the August 2007 listserv on transporting containers.

August 28, 2006

New Transporter List Available Online!

The Missouri Department of Natural Resources has recently made available an electronic list of licensed hazardous waste transporters. The list will be updated monthly to reflect any changes in licensed transporters and the date of the latest update can be found on the top of the list. Now you as the generator have a place online where you can independently verify that your hazardous waste transporter has a current license. You can also sort transporters by name, state, transporter identification, etc. by clicking the top of each column. If you have any questions regarding hazardous waste transporters, please contact Jennifer Johnson of the department's Compliance and Enforcement Section at 573-751-7560.

Nov. 18, 2005

Are you in compliance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)? The U.S. Department of Transportation (US DOT) requires everyone who offers a hazardous material for shipping to be trained. Offering material for shipping includes making a determination of its hazard, labeling containers, filling packages, signing manifests, etc. Even if you use a transporter to pick up your hazardous waste, you and your employees must still be trained.

Hazardous Materials Safety Administration's training information page.

And click here for information on free US DOT training.

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If you need further assistance, please email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

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