1. 1 Reusable Industrial Packaging Association Hazardous Materials Employee Training 2015 Edition Title 49 Code of Federal Regulations §172.700 ‑ 172.704

2. 2 Why Training? The U.S. Department of Transportation (DOT) requires employees whose jobs have a connection to Hazardous Materials (“hazmat”) to be trained about the recognition, regulation and proper handling of these materials. Many kinds of drums and other packagings are used for the shipment of hazmat.

3. 3 Why Training (continued) ? Training is required because in your job, you: Perform tasks with hazmat packaging, Prepare packagings for hazmat use, or Provide packagings to hazmat shippers. Required every 3 years, and 90 days from new hire

4. 4 Types of Hazmat Training Section I. General Awareness Training (Including Hazmat “Security Awareness”) Section II: Function-Specific Training (Including Tests for Packagings) Section III: Safety & Emergency Training

5. 5 Section I: General Awareness Training Hazmats pose risks to safety, health and the environment. U.S. rules for packaging and shipping hazmats are set by the Department of Transportation (DOT).

6. 6 Hazmat Basics The following slides will explain: Bulk, Non-Bulk and Intermediate Bulk Containers The Hazardous Materials Table Classes of Hazardous Materials 1-9 DOT Packing Groups I, II, III Hazard Levels X, Y, Z Proper Shipping Name / UN Number Package Labels Vehicle Placards Shipping Papers

7. 7 Bulk, Non-bulk and Intermediate Bulk Containers Bulk containers are those greater than 119 gallons. Non-bulk containers are 119 gallons or less (for example, 55-gallon drums). Intermediate Bulk Containers are often referred to as “IBCs”; they are typically 260-300 gallons; some regulations are written specifically for IBCs

8. 8 DOT Packing Groups A hazardous material’s Packing Group reflects the level of hazard and determines the mark required on the packaging. Packing Group Degree of Hazard Packaging Mark I most serious X II moderate hazard Y III low hazard Z

9. 9 Package Labels Diamond-shaped; they communicate the hazard with text and images. Examples:

10. 10 Packaging Marks: Design Types A three-part code indicates the packaging “design-type”. 1. Drums A. Steel1. Closed Head 2. Barrels B. Aluminum2. Open Head 3. Jerricans C. Wood 4. Boxes G. Fibre 5 Bags H. Plastic 6. Composite "1A1" is a closed-head steel drum; “1H2" is an open-head plastic drum, etc.

11. 11 Markings (Example: drum for liquids) 1=drum A=steel 1=Tight Head Specific Gravity of Liquid Packing Group unun 1A1/Y1.2/100/10 USA/M1234/ R L Vapor pressure of Liquid (kPa) Manufacturer’s or Reconditioner’s Identity Number Registered with US DOT Country of Manufacture Year of Manufacture UN Symbol R = Reconditioned L = Leakproof Tested

12. 12 DOT Registration Numbers In place of marking containers with their name and address, manufacturers and reconditioners can receive a registration number from the U.S DOT. Registered numbers are 4-digits, preceded by an “R” or an “M”. For example: M1234.

13. 13 Bottom embossment for steel drums The bottom must be permanently marked (embossed with basic specifications: Example: UN 1A1 / Y 1.4 / 200 / 08 1.2 0.9 1.2 1.2/0.9/1.2 is thickness in mm (top, body, bottom) Drum would be marked (lower line) simply “1.0” for a drum that is “all-1mm” throughout the body and heads.

14. 14 Closure Instructions All manufacturers, reconditioners and distributors of hazmat packagings must provide users with written instructions on closing the packagings. Typically, written closure instructions can be obtained from the manufacturers of packagings and closures. RIPA can provide members with sample closure instructions for drums and IBCs.

15. 15 Intermediate Bulk Containers (IBCs) Some are flexible IBCs Others are all metal or all plastic (rigid) Some are “Composite IBCs” : Bottle-in-a-Cage Typically 260 – 300 gallons DOT has separate rules for IBCs

16. 16 Examples of Composite IBCs

17. 17 Composite IBC Mark (Example) 31HA1/Y/12 10/USA/ M1234 / 4067 /1066 1070L / 73kg / 100 kPa /12 14 / 12 14 Note: December 2014 (12 14) is date of last leakproofness test, and last complete inspection. unun

18. 18 Leakproofness Testing IBCs IBCs intended for hazmat liquids (or hazmat solids discharged under pressure) must be inspected externally and leakproofness tested every 2 ½ years. All IBCs must be internally inspected at least every 5 years

19. 19 DOT Hazmat Security Awareness (Anti-terrorism) Hazardous materials, in storage or in transport, could be targeted by certain individuals or groups for use as lethal and destructive tools. Companies shipping certain hazardous materials (e.g. explosives, radiological materials) are required to have written Security Plans to address the risks that someone might attempt to take control of the materials and use them for violent purposes. For RIPA members, only “security awareness” training is required (and as provided here).

20. 20 Hazmat Security (continued) All employees must be aware that hazardous materials, hazmat packagings and/or packagings with residues of hazmat could be used by groups or individuals to cause deliberate harm. Employees having any suspicion that a party to any transaction or shipment might be planning malicious use of hazardous materials or hazmat packagings should consult immediately with their supervisor. Employers required to have Security Plans are also required to instruct those employees who have access to hazardous materials in the details and the implementation of the Plan. Your employer will inform you if you need this additional training.

21. 21 Section II: Function-Specific Training Know Your Hazmat Responsibilities Specific skills and knowledge are needed to perform a particular job. Be sure you know what to do, and if you do not, ask for guidance on any hazmat or packaging issue.

22. If Your Job Includes Running Tests on Packagings, Be Prepared to…… Show Documents Used to Test Properly, such as: 49 CFR Hazmat Regulations 178.600 Testing Non-Bulk Packaging 178.800 Testing IBCs ASTM Test Guides RIPA / ISDI Test Guide for Steel Drums 22

23. 23 “Production” Leakproofness Testing Every reconditioned drum or pail, and every repaired IBC must be tested for leakproofness prior to use in shipping hazmat. There are certain methods of testing approved under the regulations. The most common method is that of applying pressure to the inside of the container and checking for leaks Many drum reconditioners check for leaks by submerging drums in a water bath and looking for bubbles.

24. 24 “Production” Testing (continued) The level of pressure applied depends on the performance rating of the drum: X, Y or Z. The higher the rating (for instance “X”), the higher the pressure. If one of your job functions is to conduct the leak test on containers as they move through the plant, your employer will instruct you on how to operate that work station, how long to hold pressure, and how to remove and dispense with containers that fail the test.

25. 25 “Design-Type” Testing (Non-Bulk Packgings) These tests qualify (certify) a packaging design as a “UN” packaging for hazmat use: Drop Test Hydrostatic Pressure Test Leakproofness Test Stacking Test Vibration Test

26. 26 Recordkeeping The required test report elements are: Name and address; Test report number; Date of the test report; Manufacturer of the packaging; Description of the packaging which may include drawing(s) and/or photographs(s); Maximum capacity; Characteristics of test contents, e.g., viscosity and relative density for liquids; Test descriptions and results. The test report should be signed with the name and status of the signatory.

27. 27 Drum Reconditioning Drum reconditioning typically includes functions such as: De-labeling Chaining / shot blast (for steel) Wash or burn Painting / lining Leakproofness test Marking / labeling

28. 28 Minimum Thickness for Reconditioning in U.S. Steel drums (55 gallon) marked either: 1.2 / 0.9 / 1.2 mm or 1.0 mm always meet DOT minimum thickness for reuse with hazmat The actual U.S. minimum thicknesses for such steel drums are are 1.11 / 0.82 / 1.11 and 0.92 throughout. Steel drums marked 1.1 / 0.8 / 1.1 may meet actual minimums after considering the +/- tolerances (variances) in the thicknesses (see graphic of +/- variances on next slide). Plastic Drums (55 gallon): must be 2.2 mm minimum throughout.

29. 29

30. 30 Reconditioner’s Drum Markings Durable side mark (e.g. label or stencil) Re-applied by reconditioner Same as manufacturer’s mark but must also show: Country code (USA); Reconditioner’s address or registered symbol or number (e.g., M1234); Month & year (last two digits); “R” (reconditioned); “L” (leakproof tested).

31. 31 Example: Reconditioner’s Durable Side Mark (tight-head drum for liquids) 1A1/Y1.2/100 USA/Mxxxx/14 RL “R” indicates reconditioned “L” indicates leakproof tested unun

32. 32 Drum Remanufacturing Rebuilding tight-head drums Converting tight-head drums to open-head drums Converting non-UN drums to UN-type hazmat drums Remanufacturing triggers the requirements for full design-type testing and certification.

33. 33 3 Types of IBC “Reprocessing” 1.IBC Routine Maintenance 2. IBC Repair 3. IBC Re-manufacturing

34. 34 “Routine Maintenance” of IBCs Cleaning. Removal and reinstallation or replacement of body closures and gaskets or service equipment meeting the original manufacturer's design type. (Note: must verify “leaktightness” of reinstalled or replaced closures and service equipment; full leakproofness test under pressure is not required). Restoration of “non-containment” parts such as legs and lifting attachment.

35. 35 Reconditioner’s Marking on “Routinely Maintained” Composite IBCs The reconditioner places near the original IBC UN mark -which is retained or re-applied by the reconditioner – the following: Country code (e.g., USA) Name, registered symbol or registered number (e.g., Mxxxx) of company. Example USA / M1234

36. 36 “Repair” of Composite IBCs The repair of FIBCs, rigid plastic IBCs and inner plastic bottles is not authorized. Replace damaged bottles with new bottles conforming to the original IBC manufacturer's specification. Conduct leakproofness test on repaired IBCs. New, replacement bottles should come already tested! US DOT is considering the issuance of company-specific Approvals to NOT re-test. Record the date of the test

37. 37 Marking Repaired Composite IBCs Original IBC marks are retained or re-applied. The company that tests and inspects the repaired IBC applies the following near the original IBC mark: Country Symbol (M number) Month and year of tests and inspections. Example USA / M1234 / 01 14

38. 38 Shipments Off-Site of Hazardous Waste Some reconditioners will generate as part of operations certain waste that is regulated as hazardous by the U.S. Environmental Protection Agency. Training, shipping and other rules could apply, depending on volumes.

39. 39 Section III: Safety Training Emergency Response Employee Protection Avoiding Workplace Accidents

40. 40 Emergency Response First priority is protection of health and safety. Second priority is protection of property and the environment.

41. 41 Emergency Response Steps In the event of a hazmat spill: Clear the area of workers; Notify plant supervisor and emergency response personnel; Avoid inhaling fumes, smoke or vapors of spilled materials; Don’t touch leaking containers, even to check labels; If you don’t NEED to be be in the area, leave.

42. 42 Emergency Response (Medical) Offer first aid or obtain professional medical assistance for anyone who may have been injured. Employees should have access to “Safety Data Sheets” (SDS) which contain first aid information; your employer will instruct you on where these sheets are kept. Some employers post 24-hour phone numbers to call and request that an SDS be sent by fax. In a medical emergency, do not hesitate to call the SDS number or dial 911 for help.

43. 43 Employee Protection Your employer will provide protective clothing and equipment (for example, gloves, eye goggles, etc.) to reduce the risk of exposure to hazmat while on the job. Your employer will provide proper ventilation in the building to minimize exposure to hazmat. If you are not sure about something in terms of safety, ask!

44. 44 Certification of Hazmat Employee Training and Knowledge Test Compliance with Hazardous Materials Regulations For Employee Training: 49 CFR §172.700-704 Name of Hazmat Employee: Employer: Training Materials Used: PowerPoint Presentation Developed by the Reusable Industrial Packaging Association, Rockville, MD 301/577-3786; www.reusablepackaging.org Date and Place Training Completed: Training Administered by: Name, Company, Address

45. You Are Not Yet Done…. Now You Must Train Your Personnel Create a Certificate for Each Employee and Place it in their File After they have reviewed these slides and taken the following written test (there is no pass or fail grade): 45

46. 46 Test Questions Part I General Awareness Training 1) Which U.S. government agency regulates the packaging and transportation of hazardous materials (hazmats)?__________________________________________ 2) Which of the following marks on a hazmat packaging represents the most hazardous material? X, Y, or Z_________ 3) Under the Hazardous Materials Regulations, are 55-gallon steel and plastic drums considered “bulk” or “non-bulk” packaging? ___________________________ 4) “IBC” stands for__________________________________ 5) Is a drum marked “1A1” a steel tight-head drum or a steel open-head drum?____________ 6) A drum marked “1H1” is made of_________________ 7) Steel drums used for hazmats must have permanent marks on the ______________of the drum. 8) Hazmat employees must receive refresher training and be re-tested at least once every ___ years 9) Providers of hazmat packagings, including reconditioners and distributors, must provide customers a copy of the written instructions for proper ____________

47. 47 Part II Function-Specific and Safety Training 10) True or False: steel and plastic drums in the U.S. must meet regulations for minimum thickness in order to be reconditioned? True _____ False_____ 11) Is the conversion of a drum from a tight-head drum to an open-head (removable-head) drum considered “reconditioning” or “remanufacturing”?________________________ 12) Reconditioners must apply a durable mark (for example, a stencil or a label) to the __________of the container. 13) The reconditioner’s mark on a reconditioned drum includes the letters “R” and the letter ________ for drums intended to hold liquids. 14) The letter “L” indicates the drum or container has been tested for_____________________ 15) IBCs with an inner plastic “bottle” and an outer metal “cage” are referred to as __________ IBCs. 16) IBCs must be inspected and leak tested at least every _________years. 17) Choose one: Rigid plastic IBCs and inner bottles for composite IBCs that are cracked, warped or corroded can or cannot be repaired and returned to service.__________ 18) Regarding security awareness (anti-terrorism): Hazardous materials potentially could be used by certain groups or individuals for violent, destructive purposes. An employee with concerns about the safety or security of any particular packaging, shipment or transaction should consult immediately with his/her ___________________.

48. 48 Answers 1) Department of Transportation 2) “X” 3) non-bulk 4) Intermediate Bulk Container 5) tight-head 6) plastic 7) bottom 8) three 9) closure 10) True 11) remanufacturing 12) side 13) “L” 14) leakproofness 15) composite 16) 2 ½ 17) cannot 18) supervisor