3PL Hazmat Guidance
TIA Hazmat Guidelines for 3PLs
If a broker simply connects a shipper with a carrier to move hazardous materials, the broker does not have to register with the Department of Transportation (DOT). If the broker performs any of the pre-transportation functions, as defined in section 171.8 of the Hazardous Materials Regulations they do need to register with DOT. A pre-transportation function is defined as:
” Pre-transportation function means a function specified in the HMR that is required to assure the safe transportation of a hazardous material in commerce, including—
(1) Determining the hazard class of a hazardous material.
(2) Selecting a hazardous materials packaging.
(3) Filling a hazardous materials packaging, including a bulk packaging.
(4) Securing a closure on a filled or partially filled hazardous materials package or container or on a package or container containing a residue of a hazardous material.
(5) Marking a package to indicate that it contains a hazardous material.
(6) Labeling a package to indicate that it contains a hazardous material.
(7) Preparing a shipping paper.
(8) Providing and maintaining emergency response information.
(9) Reviewing a shipping paper to verify compliance with the HMR or international equivalents.
(10) For each person importing a hazardous material into the United States, providing the shipper with timely and complete information as to the HMR requirements that will apply to the transportation of the material within the United States.
(11) Certifying that a hazardous material is in proper condition for transportation in conformance with the requirements of the HMR.
(12) Loading, blocking, and bracing a hazardous materials package in a freight container or transport vehicle.
(13) Segregating a hazardous materials package in a freight container or transport vehicle from incompatible cargo.
(14) Selecting, providing, or affixing placards for a freight container or transport vehicle to indicate that it contains a hazardous material.
To register with the Pipeline Hazardous Materials Safety Administration (PHMSA), please visit the following registration page.
Each individual who transports or offers for transport of hazardous materials (hazmat) is a hazmat employer or employee. The Federal Hazardous Materials Regulations (HMR) requires hazmat employers to train, test, and maintain records of this training for all their hazmat employees.
If you have any questions please contact Chris Burroughs at firstname.lastname@example.org or (703) 299-5705.