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  1. #1
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    HAZMAT Virgin(s) Need Advice

    Just recently, our company acquired two heavy hitting clients for our recycling business in Orlando, FL. So far, I have taken the necessary steps to obtain my HAZMAT endorsement, as these companies will eventually require HAZMAT recycling as part of the written contract. To be a little more specific, we will be hauling mass quantities of batteries and fluorescent light bulbs. On a side note, I have not been able to find a HAZMAT classification for fluorescent light bulbs, and mercury is classified as a forbidden HAZMAT in the index table. Both myself and the company are new to transporting and recycling HAZMATs and are almost clueless as to where to start on getting our truck legal for transporting HAZMATs and how to classify fluorescent light bulbs for transport to our end of life recycler. Any help on this topic would be greatly appreciated.

  2. #2
    Medium Load Member wis bang's Avatar
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    Every hazard classification has a 'generic' description of sorts, including wastes.

    It may fall under one like Hazardous waste, solid, NOS, and require additional information describing the hazardous element. The NOS means 'not otherwise specified [by name]'

  3. #3
    Trucker Forum STAFF Lilbit's Avatar
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    Here's one place for you to start, FMCSA. I don't know where you have been looking so far. I haven't dealt with Haz Mat since before the changes after 9/11, so I'm really, really rusty on it!

  4. #4
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    Quote Originally Posted by orlandorecycles View Post
    Just recently, our company acquired two heavy hitting clients for our recycling business in Orlando, FL. So far, I have taken the necessary steps to obtain my HAZMAT endorsement, as these companies will eventually require HAZMAT recycling as part of the written contract. To be a little more specific, we will be hauling mass quantities of batteries and fluorescent light bulbs. On a side note, I have not been able to find a HAZMAT classification for fluorescent light bulbs, and mercury is classified as a forbidden HAZMAT in the index table. Both myself and the company are new to transporting and recycling HAZMATs and are almost clueless as to where to start on getting our truck legal for transporting HAZMATs and how to classify fluorescent light bulbs for transport to our end of life recycler. Any help on this topic would be greatly appreciated.
    Since this is a forum and not a week-long seminar I'll try to briefly point you in the right direction.

    1. Spent fluorescent light tubes are RCRA regulated hazardous waste. You are about to enter the EPA's world (although you don't get to leave USDOT's world).
    2. EPA's hazardous waste regulations are found in 40 CFR.
    3. Your company will be defined as a hazardous waste transporter.
    4. As a transporter the USEPA requires that your company
    a) Obtain an EPA Identification Number
    In Florida you can get your EPA ID Number from:
    Florida Department of Environmental Protection
    MS 4555
    2600 Blair Stone Road
    Tallahassee FL, 32399-2400
    850-245-8748
    b) Comply with the manifest system (the waste generator is responsible for properly classifying the waste and completing the manifest. The Uniform Hazardous Waste Manifest will serve as your shipping paper and has specific disposition and retention requirements)
    c) Respond appropriately to Hazardous Waste Discharges (this will require some training of employees).
    d) Comply with all applicable USDOT regulations. Because the PHMSA regulations (49 CFR 171 - 179) include hazardous wastes in the definition of Hazardous Materials, the haz mat regulations apply.

    Hope this helps.

  5. #5
    Bobtail Member
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    Thanks everyone for all your help so far. We do currently have an EPA number, but still need to obtain a DOT number. I'll definitely fill the boss in on what you've all told me so far, and try to get the ball rolling on this thing. Any future help or advice is greatly appreciated, so keep it coming.

  6. #6
    Trucker Forum STAFF Lilbit's Avatar
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    Other links on that page I linked to will give you the pages to get set up with your DOT number. That can even be done online now.