General REgulatory information
The safe transportation of hazardous materials is regulated by the US Department of Transportation (DOT), the US Environmental Protection Agency (EPA) and the Wisconsin Department of Natural Resources (DNR), among others. The Pipeline and Hazardous Materials Safety Administration (PHMSA) unit within the DOT is primarily responsible for the oversight of hazardous materials movement, while the DOT Hazardous Materials Regulations (HMR) regulate the safe and secure transportation of hazardous materials in commerce (49 CFR 171-177).
Some materials not offered in commerce and transported by governmental agencies for official purposes are exempt from DOT hazardous materials provisions. It is still necessary to ensure safety during transport and proper communication to first responders in the event of an accident. Procedures for these activities must provide a level of safety equivalent to that provided under the hazardous materials regulations. This includes training, packaging, marking, labeling and documentation. DOT provisions are a good best practices standard even when not required.
Training Requirements
Anyone who prepares, marks, labels, certifies packages or signs shipping papers, including hazardous waste manifests and air waybills, for transportation by a non-governmental agency (e.g., waste contractor, FedEx, UPS) are acting in commerce and are subject to the HMR regulations. This includes people who sign hazardous waste manifests. The training requirements can be found in 49 CFR 172 subpart H and are briefly summarized below. Additional information on signing authority considerations for waste manifests and documentation is also provided on the UW Signatory Authority webpage.
- Hazmat employee training is required in the following subject areas:
(1) General awareness/familiarization
(2) Function-specific training
(3) Safety training
(4) Security awareness training
(5) In-depth security plan training - Training records must include:
(1) The hazmat employee’s name
(2) The most recent training completion date of the hazmat employee’s training
(3) A description, copy or the location of the training materials used to meet the requirements of this section
(4) The name and address of the person providing the training
(5) Certification that the hazmat employee has been trained and tested - Initial and recurrent training:
(1) Hazmat employees shall receive initial training within 90 days after employment or a change in job function
(2) Hazmat employees must receive the training required by this subpart at least once every three years
university of wisconsin Policies & best practices
Use of personally owned vehicles on university business
University officers, employees and agents may drive their personally owned vehicles on university business. In the event of a loss, however, their personal auto liability insurance will be primary to the State coverage. The State will only provide excess liability coverage to drivers when they are using their personally owned vehicles and coverage for damage to the personally owned vehicle is not provided. For that reason, all drivers using their personally owned vehicle shall complete the driver authorization process prior to the trip and should carry personal auto liability insurance with limits of at least $100,000/$300,000/$50,000.
Transporting work-related hazardous materials in a personal vehicle is not recommended and may be prohibited by campus policy. Some insurance carriers will not cover an accident claim if it involves work-related materials. Many personal vehicle insurance policies include a business-use exclusion. If you plan on using a personal vehicle on university business, consult your insurance carrier for information on coverage. Inform your carrier if that business involves transporting hazardous materials.
Emergency Phone number for Hazmat Shipments
UW-Madison Environment, Health & Safety and UWSA maintain a service contract to provide emergency response for outgoing shipments of hazardous materials, excluding waste. For more detail, UW System employees may login to and access the VelocityEHS page.
Additional resources
- UWSA Online Training
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Hazmat quiz - 2009 State of Wisconsin Hazardous Materials Training: Shipping & Signing Manifests (video)
- US DOT Enhanced Security Requirements
- US DOT PHMSA Hazmat Outreach and Training
- US DOT PHMSA Hazardous Materials Training Modules
- The International Air Transport Association (IATA)
- UW-Madison Hazardous Materials Transportation Information
- UW-Milwaukee Hazardous Materials Transportation Information
Disclaimer
This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.