NITRATE FILMNITRATE FILM

TRANSPORTATION TRANSPORTATION REGULATIONSREGULATIONS

AMIA 2005, Austin

Rosa GaiarsaCollection Services ManagerUCLA Film & Television Archive

First transportation First transportation guidelinesguidelines

First version of First version of Recommendations on Recommendations on the Transport of Dangerous Goods, the Transport of Dangerous Goods, RTDGRTDG, published in , published in 19561956 by the by the UNUN

United Nations Economic and Social Council’s United Nations Economic and Social Council’s

Committee of Experts on the Transport of Dangerous GoodsCommittee of Experts on the Transport of Dangerous Goods

http://www.unece.org/trans/danger/publi/unrec/http://www.unece.org/trans/danger/publi/unrec/rev14/14files_e.htmlrev14/14files_e.html

UN Recommendations UN Recommendations (RTDG)(RTDG)

The document is regularly amended The document is regularly amended to align with new technologies and to align with new technologies and changing needs of userschanging needs of users

The document itself has no legal The document itself has no legal force except when adopted in force except when adopted in agreements and/or domestic agreements and/or domestic legislationlegislation

US - Regulatory historyUS - Regulatory history

1975 –1975 – Transportation Safety ActTransportation Safety Act

Established the Established the National Transportation National Transportation Safety BoardSafety Board as an independent agency as an independent agency and authorized the Secretary to…and authorized the Secretary to…regulate the transportation of all regulate the transportation of all hazardous materials, and to impose both hazardous materials, and to impose both civil and criminal penalties for violations civil and criminal penalties for violations of those regulationsof those regulations

US - Regulatory evolutionUS - Regulatory evolution

1977 – 1977 – Transportation Safety Institute Transportation Safety Institute and other agencies are consolidated and other agencies are consolidated into the into the Research and Special Programs Research and Special Programs Administration, Administration, RSPARSPA

2004 – 2004 – RSPA RSPA reorganizedreorganized into into Pipeline Pipeline and Hazardous Materials Safety and Hazardous Materials Safety Administration, Administration, PHMSAPHMSA

http://hazmat.dot.gov/

US - Regulatory CodeUS - Regulatory Code

All modes of transportation of All modes of transportation of dangerous goods are regulated dangerous goods are regulated by the by the Department of Department of Transportation’s Code of Federal Transportation’s Code of Federal Regulations,Regulations, CFR49CFR49

http://www.myregs.com/dotrspahttp://www.myregs.com/dotrspa

Four Modal RegulationsFour Modal Regulations

Highway Highway RailRail Water Water AirAir

InternationalInternational regulations - regulations - AirAir

ICAOICAO: International Civil Aviation : International Civil Aviation Organization’s Standards and Recommended Organization’s Standards and Recommended Practices – Practices – Technical Instructions for the Technical Instructions for the Safe Transport of Dangerous Goods by AirSafe Transport of Dangerous Goods by Air http://www.icao.inthttp://www.icao.int

IATAIATA: International Air Transport : International Air Transport Association’s Association’s Dangerous Goods RegulationsDangerous Goods Regulations (more restrictive than ICAO – updated (more restrictive than ICAO – updated annually) annually) http://www.iata.orghttp://www.iata.org

Basic shipment Basic shipment requirementsrequirements

ClassificationClassification Identification Identification PackagingPackaging Marking and labelingMarking and labeling DocumentationDocumentation TrainingTraining

Classification – UN criteriaClassification – UN criteria Class 1 – ExplosivesClass 1 – Explosives Class 2 – Gases Class 2 – Gases Class 3 – Flammable liquidsClass 3 – Flammable liquids Class 4 – Flammable solidsClass 4 – Flammable solids Class 5 – Oxidizing SubstancesClass 5 – Oxidizing Substances Class 6 – Toxic and infectious Class 6 – Toxic and infectious

substancessubstances Class 7 – Radioactive materialClass 7 – Radioactive material Class 8 – CorrosivesClass 8 – Corrosives Class 9 – Miscellaneous DGClass 9 – Miscellaneous DG

Class 4 subdivisionClass 4 subdivision

4.1 Flammable solids4.1 Flammable solids

4.2 Substances liable to 4.2 Substances liable to spontaneous combustionspontaneous combustion

4.3 Substances which, in 4.3 Substances which, in contact with water, emit contact with water, emit flammable gases (dangerous flammable gases (dangerous when wet) when wet)

Identification / Packing Identification / Packing groupgroup

Proper shipping nameProper shipping nameFilms, nitrocellulose baseFilms, nitrocellulose base

UN / IDUN / IDUN1324UN1324

Packing groupPacking group Group I (X): high dangerGroup I (X): high danger Group II (Y): medium danger (IATA)Group II (Y): medium danger (IATA) Group III (Z): low danger (CFR)Group III (Z): low danger (CFR)

UN certified outer packageUN certified outer package

Example:Example:

Fiberboard boxFiberboard box

UN 4GUN 4G

Buyers beware: Buyers beware: request copy of test request copy of test report from report from manufacturer and/or manufacturer and/or supplier of supplier of packaging materialspackaging materials

Packaging typesPackaging types

Inner packageInner package: film can or box: film can or box

Outer packageOuter package: list of fourteen : list of fourteen containers that are tested and containers that are tested and certified by UN specificationscertified by UN specifications

OverpackOverpack: to bundle outer : to bundle outer packages for shipmentpackages for shipment

Packing instructions IATAPacking instructions IATA

Y400Y400 Limited quantitiesLimited quantities: :

1 kg per inner package 1 kg per inner package 10 kg (22 lbs) net weight10 kg (22 lbs) net weight

400400 Passenger and cargo aircraft:Passenger and cargo aircraft:

25 kg (55 lbs) 25 kg (55 lbs) Cargo aircraft only: Cargo aircraft only:

100 kg (220 lbs)100 kg (220 lbs)

Marking and labelingMarking and labeling Shipment label: Shipment label:

shipper and shipper and consignee infoconsignee info

Hazard labelHazard label Proper shipping nameProper shipping name UN/ID numberUN/ID number Multiple packages ID Multiple packages ID

mark on overpackmark on overpack Net quantity info in kgNet quantity info in kg Overpack notice Overpack notice Air eligibility labelAir eligibility label

Placarding – CFR49Placarding – CFR49 Vehicles transporting Vehicles transporting

more than 1001 lbs (454 more than 1001 lbs (454 kg) of nitrate film have to kg) of nitrate film have to be placardedbe placarded

It’s the responsibility of It’s the responsibility of the shipper to provide the shipper to provide the proper placards to the proper placards to the carrierthe carrier

If you offer for shipment If you offer for shipment an amount of nitrate film an amount of nitrate film that requires placarding, that requires placarding, registration with the DOT registration with the DOT is requiredis required

DocumentationDocumentation

Shipper’s Shipper’s Declaration of Declaration of Dangerous GoodsDangerous Goods

Two copies required by Two copies required by law, but some carriers law, but some carriers require three copiesrequire three copies

Papers have to be Papers have to be retained for 375 days retained for 375 days after the material is after the material is accepted by the initial accepted by the initial carriercarrier

Emergency telephone Emergency telephone numbernumber

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

Emergency phone / Emergency phone / requirementsrequirements

Person must be knowledgeable of the Person must be knowledgeable of the hazardous material being shippedhazardous material being shipped

Person must have comprehensive Person must have comprehensive emergency response and incident emergency response and incident mitigation information for the materialmitigation information for the material

Phone must be monitored at all times, Phone must be monitored at all times, 24/724/7

Answering service, answering machine, or Answering service, answering machine, or beeper devices are not accepted beeper devices are not accepted

Emergency phone / optionsEmergency phone / options

The telephone number must be the The telephone number must be the number of the person offering the number of the person offering the hazardous material for transportation orhazardous material for transportation or

The number of an agency or The number of an agency or organization capable and responsible organization capable and responsible for providing detailed information for providing detailed information concerning the hazardous materialconcerning the hazardous material

Emergency phone / service Emergency phone / service providersproviders

USUS ChemtrecChemtrec Chem-telChem-tel InfotracInfotrac 3E Company3E Company

CanadaCanada CanutecCanutec

http://hazmat.dot.gov/pubs/erg/erg2004.pdf

Hazmat TrainingHazmat Training

Employer is responsible for Employer is responsible for compliance with training compliance with training requirementsrequirements

Training may be provided by the Training may be provided by the employer or other public or employer or other public or private sourcesprivate sources

Employee has to be trained within Employee has to be trained within 90 days of employment90 days of employment

Employee has to be re-trained Employee has to be re-trained every 24 months (IATA) every 24 months (IATA)

Training contentTraining content

General awarenessGeneral awareness Function-specific trainingFunction-specific training Safety trainingSafety training Awareness training of transportation Awareness training of transportation

security risk (CFR, added in 2003)security risk (CFR, added in 2003) In-depth training of security plan In-depth training of security plan

(CFR, added in 2003)(CFR, added in 2003)

Testing and Testing and documentationdocumentation

After training, Hazmat employee After training, Hazmat employee has to be tested and provided with has to be tested and provided with a certificate of training completiona certificate of training completion

Training records have to be kept Training records have to be kept and made available to and made available to enforcement agents upon demandenforcement agents upon demand

http://hazmat.dot.gov/training/training.htm

CFR49 / Materials of trade CFR49 / Materials of trade exceptionexception

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

Materials of trade regulationsMaterials of trade regulations

Less restrictive packagingLess restrictive packaging

Less restrictive marking and Less restrictive marking and labelinglabeling

Limit of 30 kg (66 lbs) per packageLimit of 30 kg (66 lbs) per package

Aggregate gross weight may not Aggregate gross weight may not exceed 200 kg (440 lbs)exceed 200 kg (440 lbs)

Better safe than sorryBetter safe than sorry

Any violation of a requirement of the Federal Any violation of a requirement of the Federal hazardous material transportation law is liable hazardous material transportation law is liable for a civil penalty of not more than $32,500 for a civil penalty of not more than $32,500 and not less than $275 for each violationand not less than $275 for each violation

Federal law forbids the carriage of hazardous Federal law forbids the carriage of hazardous materials aboard aircraft in your luggage or on materials aboard aircraft in your luggage or on your person. A violation can result in five years' your person. A violation can result in five years' imprisonment and penalties of $250,000 or imprisonment and penalties of $250,000 or moremore

NITRATE FILMNITRATE FILM

DISPOSAL DISPOSAL

REGULATIONSREGULATIONS

AMIA 2005, Austin

Rosa GaiarsaCollection Services ManagerUCLA Film & Television Archive

US - Regulatory historyUS - Regulatory history

1965 – 1965 – Solid Waste Disposal Act Solid Waste Disposal Act waswas signedsigned

1970 – 1970 – Environmental Protection Agency Environmental Protection Agency was createdwas created

1976 – 1976 – Resource Conservation and Resource Conservation and Recovery Act Recovery Act was signedwas signed

http://www.epa.gov/epaoswer/general/k02027.pdf

US – Regulatory codeUS – Regulatory code

Tracking and permittingTracking and permitting to monitor and to monitor and control hazardous wastecontrol hazardous waste

Strict Strict requirements for storage, treatment requirements for storage, treatment and disposaland disposal of hazardous waste of hazardous waste

Authorized States to implementAuthorized States to implement RCRA’s RCRA’s waste management program waste management program

1980: RCRA published the 1980: RCRA published the Hazardous Waste Hazardous Waste and Consolidated Permit Regulationsand Consolidated Permit Regulations

Regulatory amendmentRegulatory amendment

Regulated businesses that generated Regulated businesses that generated even even small amountssmall amounts of hazardous waste of hazardous waste

1984 - Hazardous and Solid Waste 1984 - Hazardous and Solid Waste AmendmentsAmendments

http://www.epa.gov/epaoswer/general/orientat/romtoc.pdf

Hazardous Waste identificationHazardous Waste identification

ListedListed CharacteristicsCharacteristics

IgnitableIgnitable CorrosiveCorrosive ReactiveReactive ToxicToxic

Waste generator Waste generator classificationsclassifications

Large quantity generator (LQG)Large quantity generator (LQG) 1000 kg (2200 lbs) or more of hazardous 1000 kg (2200 lbs) or more of hazardous

waste per monthwaste per month Small quantity generator (SQG)Small quantity generator (SQG)

More than 100 kg (220 lbs) but less than More than 100 kg (220 lbs) but less than 1000 kg per month1000 kg per month

Conditionally exempt small quantity Conditionally exempt small quantity generatorgenerator (CESQG) (CESQG) Less than 100 kg (+/- 45x1000ft cans) Less than 100 kg (+/- 45x1000ft cans)

per monthper month

State regulations*State regulations*

State regulations may be more State regulations may be more strict than Federal requirementsstrict than Federal requirements

Some States require CESQGs to Some States require CESQGs to follow some of the SQGs follow some of the SQGs requirementsrequirements

** Generators need to contact their Generators need to contact their respective state agency to determine if respective state agency to determine if state regulation differs from federal state regulation differs from federal requirementsrequirements

Requirements for Requirements for SQGsSQGs

Obtain an Obtain an EPA identification numberEPA identification number from your from your State Environmental OfficeState Environmental Office

Comply with Comply with accumulation and storage accumulation and storage requirementsrequirements

Comply with requirements for Comply with requirements for training, training, contingency planning and emergency responsecontingency planning and emergency response

Prepare the waste for shipment (Prepare the waste for shipment (packaging, packaging, labeling, marking, placardinglabeling, marking, placarding))

Comply with the Comply with the manifest systemmanifest system Meet Meet record keeping and reportingrecord keeping and reporting

requirementsrequirements

Accumulation and storage Accumulation and storage requirementsrequirements

CESQGs cannot accumulate more than CESQGs cannot accumulate more than 1,000 kg (2200 lbs = +/- 450 x 1000ft cans) 1,000 kg (2200 lbs = +/- 450 x 1000ft cans) of hazardous waste on site at any timeof hazardous waste on site at any time

SQGs can accumulate no more than 6,000 SQGs can accumulate no more than 6,000 kg (13,228 lbs) on site for up to 180 days kg (13,228 lbs) on site for up to 180 days without a permitwithout a permit

http://www.epa.gov/epaoswer/hazwaste/sqg/handbook/k01005.pdf

Preparation for shipment – Preparation for shipment – 49CFR49CFR

Proper shipping name: Proper shipping name: Nitrocellulose Nitrocellulose with waterwith water ((with no less than 25% water, by with no less than 25% water, by massmass))

UN/ID: UN/ID: UN 2555UN 2555 Hazard label: Hazard label: 4.14.1 Packing group: Packing group: IIII Packing instructions:Packing instructions:

Limited quantities: Limited quantities: 173.151173.151 Non-bulk: Non-bulk: 173.212173.212

Selecting Transporter and Selecting Transporter and TSDFTSDF

Your institution’s Hazmat OfficeYour institution’s Hazmat Office Local references Local references Trade associationsTrade associations Better Business BureauBetter Business Bureau City, County or State Hazmat City, County or State Hazmat

Management AgencyManagement Agency Regional EPA OfficeRegional EPA Office

(Treatment, Storage and Disposal (Treatment, Storage and Disposal Facility)Facility)

Manifest*Manifest* Required by EPA Required by EPA

and DOTand DOT Multiple copies Multiple copies

as tracking tool as tracking tool from generator from generator to transporter to to transporter to disposal facilitydisposal facility

Records retained Records retained for three yearsfor three years

* new form to be adopted in 2006

EnforcementEnforcement

EPA can use administrative, civil, or criminal EPA can use administrative, civil, or criminal enforcement actions to address RCRA enforcement actions to address RCRA violations violations

Penalty amounts are case specific Penalty amounts are case specific Penalty is calculated on base amount and a Penalty is calculated on base amount and a

multi-day componentmulti-day component EPA may reduce or waive penalties for EPA may reduce or waive penalties for

violations that are promptly disclosed and violations that are promptly disclosed and correctedcorrected

EPA contact informationEPA contact information

http://www.epa.gov/epaoswer/osw/comments.htmhttp://www.epa.gov/epaoswer/osw/comments.htm

Links to State web pages Links to State web pages and EPA regional web and EPA regional web pagespages