Registering as an Offeror or Transporter of Hazardous Materials

The New DOT Permit

by Joe Skovron

In 1992 the DOT imposed a permit system for all persons transporting dangerous goods meeting 5 defined criteria. These original 5 criteria did not usually impact the biotech / pharmaceutical industry in Seattle. However, on July 1, 2000, a 6th category will be added. The 6th category adds "offers or transports in commerce a quantity of hazardous material that requires placarding." Most dangerous goods for standard research collaborations do not require placarding. The same cannot be said quite so easily for waste shipments. Several examples of waste that require placarding regardless of quantity are Class 4.3 - Dangerous when wet, Class 6.1 - Poison inhalation hazard Zone A or B, Class 7 - Radioactive LSA. Waste organic solvents, Class 3 - Flammable liquids, require placarding if transporting > 1001 lbs. These materials are commonly disposed, thus transported, by the biotech industry. (Please see 49CFR 172.504 Table 1 and 2 for when placarding is required.) There are several DOT exemptions and approved packing systems that allow for 4.3's and 6.1's to be packaged for transport in such a way as to eliminate the need for placards. Additionally, if radioactive waste is transported as a "Limited Quantity" placarding is not required; however, clearly a limited quantity calculation would be required for each and every container.

The dangerous goods permit is $2000.00 / year. If a company qualifies as a small business, as defined by the Small Business Administration SIC codes, the permit drops to $300.00 / year.

The DOT and the Small Business Administration websites are listed below. The full text of the regulation can be found on the DOT site, while SIC codes and small business information can be found on the other.