1. TRANSPORTATION REGULATIONS
AMIA 2005, Austin
NITRATE FILM
TRANSPORTATION REGULATIONS
Rosa Gaiarsa
Collection Services Manager
UCLA Film & Television Archive

2. First transportation guidelines
First version of Recommendations on the Transport of Dangerous Goods, RTDG, published in 1956 by the UN
United Nations Economic and Social Council’s
Committee of Experts on the Transport of Dangerous Goods

3. UN Recommendations (RTDG)
The document is regularly amended to align with new technologies and changing needs of users
The document itself has no legal force except when adopted in agreements and/or domestic legislation

4. US - Regulatory history
1975 – Transportation Safety Act
Established the National Transportation Safety Board as an independent agency and authorized the Secretary to…regulate the transportation of all hazardous materials, and to impose both civil and criminal penalties for violations of those regulations

5. US - Regulatory evolution
1977 – Transportation Safety Institute and other agencies are consolidated into the Research and Special Programs Administration, RSPA
2004 – RSPA reorganized into Pipeline and Hazardous Materials Safety Administration, PHMSA

6. US - Regulatory Code
All modes of transportation of dangerous goods are regulated by the Department of Transportation’s Code of Federal Regulations, CFR49
Code is very much aligned with UN recommendations.
MODES of transportation:

7. Four Modal Regulations
Highway
Rail
Water
Air
Highway and rail modes are regulated by domestic legislation and usually included in trade agreements with neighboring countries. Examples: US / Canada / Mexico or European Community. Water and air are truly international. Water IMDG: International Maritime Dangerous Goods.

8. International regulations - Air
ICAO: International Civil Aviation Organization’s Standards and Recommended Practices – Technical Instructions for the Safe Transport of Dangerous Goods by Air
IATA: International Air Transport Association’s Dangerous Goods Regulations (more restrictive than ICAO – updated annually)
Shippers may see two specific requirements. ICAO is an Organization of the United Nations: no legal force, but adopted by nation members
IATA is an Association of Commercial Airline carriers, both passenger and cargo // What are CFR49, ICAO and IATA requirements?

9. Basic shipment requirements
Classification
Identification
Packaging
Marking and labeling
Documentation
Training
Where do you get the classification information? From a Hazardous material table

11. Classification – UN criteria
Class 1 – Explosives
Class 2 – Gases
Class 3 – Flammable liquids
Class 4 – Flammable solids
Class 5 – Oxidizing Substances
Class 6 – Toxic and infectious substances
Class 7 – Radioactive material
Class 8 – Corrosives
Class 9 – Miscellaneous DG

12. Class 4 subdivision 4.1 Flammable solids
4.2 Substances liable to spontaneous combustion
4.3 Substances which, in contact with water, emit flammable gases (dangerous when wet)

13. Identification / Packing group
Proper shipping name
Films, nitrocellulose base
UN / ID
UN1324
Packing group
Group I (X): high danger
Group II (Y): medium danger (IATA)
Group III (Z): low danger (CFR)
Packing group: UN recommends that packages manufactured to contain dangerous goods follow certain specifications and that performance tests confirm that these specifications are met. After testing the packages are marked with a system of codes.

14. UN certified outer package
Example:
Fiberboard box
UN 4G
Buyers beware: request copy of test report from manufacturer and/or supplier of packaging materials

15. Packaging types Inner package: film can or box
Outer package: list of fourteen containers that are tested and certified by UN specifications
Overpack: to bundle outer packages for shipment
Single packagings are not permitted.

16. Packing instructions IATA
Y400
Limited quantities:
1 kg per inner package
10 kg (22 lbs) net weight
400
Passenger and cargo aircraft:
25 kg (55 lbs)
Cargo aircraft only:
100 kg (220 lbs)
Weight in kg.

17. Marking and labeling Shipment label: shipper and consignee info
Hazard label
Proper shipping name
UN/ID number
Multiple packages ID mark on overpack
Net quantity info in kg
Overpack notice
Air eligibility label
Labels should be applied with same orientation, all on same side of package.

18. Placarding – CFR49
Vehicles transporting more than 1001 lbs (454 kg) of nitrate film have to be placarded
It’s the responsibility of the shipper to provide the proper placards to the carrier
If you offer for shipment an amount of nitrate film that requires placarding, registration with the DOT is required
1001 lbs +/- 100 x 2,000ft or 200 x 1,000ft cans of nitrate film.
Placard is 10.5 x 10.5 inches.

19. Documentation Shipper’s Declaration of Dangerous Goods
Two copies required by law, but some carriers require three copies
Papers have to be retained for 375 days after the material is accepted by the initial carrier

20. Emergency telephone number
A person who offers a hazardous material for transportation must provide an emergency response telephone number, including the area code or international access code, for use in the event of an emergency involving the hazardous material

21. Emergency phone / requirements
Person must be knowledgeable of the hazardous material being shipped
Person must have comprehensive emergency response and incident mitigation information for the material
Phone must be monitored at all times, 24/7
Answering service, answering machine, or beeper devices are not accepted

22. Emergency phone / options
The telephone number must be the number of the person offering the hazardous material for transportation or
The number of an agency or organization capable and responsible for providing detailed information concerning the hazardous material

23. Emergency phone / service providersUS
Chemtrec
Chem-tel
Infotrac
3E Company
Canada
Canutec

24. Hazmat Training
Employer is responsible for compliance with training requirements
Training may be provided by the employer or other public or private sources
Employee has to be trained within 90 days of employment
Employee has to be re-trained every 24 months (IATA)

25. Training content General awareness Function-specific training
Safety training
Awareness training of transportation security risk (CFR, added in 2003)
In-depth training of security plan (CFR, added in 2003)

26. Testing and documentation
After training, Hazmat employee has to be tested and provided with a certificate of training completion
Training records have to be kept and made available to enforcement agents upon demand

27. CFR49 / Materials of trade exception
Material of trade means a hazardous material other than hazardous waste that is…
-- carried by a private motor carrier in direct support of a principal business (that is not transportation)

28. Materials of trade regulations
Less restrictive packaging
Less restrictive marking and labeling
Limit of 30 kg (66 lbs) per package
Aggregate gross weight may not exceed 200 kg (440 lbs)

29. Better safe than sorry
Any violation of a requirement of the Federal hazardous material transportation law is liable for a civil penalty of not more than $32,500 and not less than $275 for each violation
Federal law forbids the carriage of hazardous materials aboard aircraft in your luggage or on your person. A violation can result in five years' imprisonment and penalties of $250,000 or more

30. NITRATE FILM DISPOSAL REGULATIONS AMIA 2005, Austin Rosa Gaiarsa
Collection Services Manager
UCLA Film & Television Archive

31. US - Regulatory history
1965 – Solid Waste Disposal Act was signed
1970 – Environmental Protection Agency was created
1976 – Resource Conservation and Recovery Act was signed

32. US – Regulatory code
1980: RCRA published the Hazardous Waste and Consolidated Permit Regulations
Tracking and permitting to monitor and control hazardous waste
Strict requirements for storage, treatment and disposal of hazardous waste
Authorized States to implement RCRA’s waste management program

33. Regulatory amendment 1984 - Hazardous and Solid Waste Amendments
Regulated businesses that generated even small amounts of hazardous waste

34. Hazardous Waste identification
Listed
Characteristics
Ignitable
Corrosive
Reactive
Toxic

35. Waste generator classifications
Large quantity generator (LQG)
1000 kg (2200 lbs) or more of hazardous waste per month
Small quantity generator (SQG)
More than 100 kg (220 lbs) but less than 1000 kg per month
Conditionally exempt small quantity generator (CESQG)
Less than 100 kg (+/- 45x1000ft cans) per month

36. State regulations*
State regulations may be more strict than Federal requirements
Some States require CESQGs to follow some of the SQGs requirements
* Generators need to contact their respective state agency to determine if state regulation differs from federal requirements

37. Requirements for SQGs
Obtain an EPA identification number from your State Environmental Office
Comply with accumulation and storage requirements
Comply with requirements for training, contingency planning and emergency response
Prepare the waste for shipment (packaging, labeling, marking, placarding)
Comply with the manifest system
Meet record keeping and reporting requirements

38. Accumulation and storage requirements
CESQGs cannot accumulate more than 1,000 kg (2200 lbs = +/- 450 x 1000ft cans) of hazardous waste on site at any time
SQGs can accumulate no more than 6,000 kg (13,228 lbs) on site for up to 180 days without a permit

39. Preparation for shipment – 49CFR
Proper shipping name: Nitrocellulose with water (with no less than 25% water, by mass)
UN/ID: UN 2555
Hazard label: 4.1
Packing group: II
Packing instructions:
Limited quantities:
Non-bulk:

40. Selecting Transporter and TSDF
(Treatment, Storage and Disposal Facility)
Your institution’s Hazmat Office
Local references
Trade associations
Better Business Bureau
City, County or State Hazmat Management Agency
Regional EPA Office

41. Manifest* Required by EPA and DOT
Multiple copies as tracking tool from generator to transporter to disposal facility
Records retained for three years
* new form to be adopted in 2006

42. Enforcement
EPA can use administrative, civil, or criminal enforcement actions to address RCRA violations
Penalty amounts are case specific
Penalty is calculated on base amount and a multi-day component
EPA may reduce or waive penalties for violations that are promptly disclosed and corrected

43. EPA contact information
Links to State web pages and EPA regional web pages