Every organization handling Dangerous Goods knows (or ought to know) that employees meeting the definition of a “hazmat employee” need to be trained in accordance with 49 CFR, Part 172, Subpart H, unless otherwise excepted. Who’s a hazmat employee? The short version of the definition, from Part 171.8, is: “A person who … directly affects…
How can you keep customer returns of Dangerous Goods compliant?
Q: Reviewing the PHMSA HM-253 Final Rule on reverse logistics issued March 31, it appears it doesn’t really address returns from consumers to suppliers or manufacturers. How do you suggest keeping these shipments compliant? You are correct. Although the new PHMSA ruling contains regulatory relief for reverse logistics shipments that originate from retail stores, it…
Reverse Logistics Addressed in PHMSA Advanced Notice of Proposed Rulemaking
The U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) is requesting input to help formulate policies regarding the transport of hazardous consumer products during the “reverse logistics” portion of the supply chain. PHMSA published an advanced notice of proposed rulemaking (ANPRM) late last week soliciting public comments in order to identify ways to reduce the…
Product Returns Present a Hazmat Challenge for Retailers
As the holidays approach, many retail companies will see an influx of product returns due to extremely liberal return policies geared to attract customers. Retailers’ employees, though, don’t always recognize the potential hazards inherent in some consumer products. As a result, they may unknowingly violate federal laws and regulations, and put many at risk. Improperly…