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April 2020
S&R of the Sun
In this month's newsletter I've included only articles related to the COVID-19 public health emergency and the response to it by USDOT & USEPA. Both Federal agenicies have offered temporary relief from some of their more mundane regulatory requirements. USDOT has offered substantial relief for both shippers and carriers of alcohol-based hand sanitizer.

As EHS professionals, we still have a job to do. That includes the safe transportation of hazardous materials and managing waste in a manner that protects the environment and human health.

If you are healthy and safe, you can make the most of this time by completing your mandatory HazMat Transportation (USDOT) and Waste Management (USEPA) training in 2020 as a webinar .

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Shipping Hand Sanitizer During the COVID-19 Public Health Emergency
Alcohol-based hand sanitizer has become an essential product and a valuable commodity during the COVID-19 public health emergency. Manufacturers, shippers, and carriers new to the Hazardous Materials Regulations (HMR) may be unaware of how it must be offered for transportation and transported as a hazardous material.  This article identifies and explains the classification of hand sanitizer as a Class 3 Flammable Liquid and explains several exceptions from regulation that are available.  
Alcohol-based Hand Sanitizer

USDOT Temporary Policy for Transportation of Alcohol-Based Sanitizer
During this public health emergency, USDOT is doing what it can to facilitate the transportation of essential HazMat, like alcohol-based hand sanitizer.  Read how USDOT’s temporary policy provides relief for manufacturers and transporters of alcohol-based hand sanitizer manufactured under FDA guidance.

Important note: Issued April 02, 2020 and revised April 10th (stay tuned for more revisions!), the Notice of Enforcement Discretion provides temporary relief from the HMR and is meant to simplify the transport of alcohol-based Hand Sanitizer during the public health emergency. It expires three (3) months from its date of issuance (July 10, 2020) or at the time when the public health emergency is over, whichever is sooner.  


USDOT Issues National Emergency Declaration for CMVs Delivering Relief During COVID-19 Public Health Emergency
Motor carriers and drivers providing direct assistance in support of relief efforts related to the COVID-19 outbreaks are granted emergency relief from Parts 390 through 399 of the Federal Motor Carrier Safety Regulations.

To learn more about COVID-19 direct assistance, read my article

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USDOT Provides Temporary Relief From HazMat Employee Training During COVID-19 Public Health Emergency
HazMat Employers are not required to provide recurrent training to HazMat Employees when their 3-year renewal date falls within the limits specified in the notice.

To learn more about temporary relief from recurrent HazMat training read my article

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I provide training and consulting services to equip your team – whether it’s just you or a group of employees – to safely ship, receive, transport or dispose of hazardous materials and waste.