***Q. One thing I found confusing is that in the module, it was stated quite definitively that the generator of the hazardous waste is the responsible party forever. Then, in the homework page, the responsibility seemed to shift to part generator, part transporter, and part cleaners. So, I'm not sure if the generator is the responsible party forever or not.
A. OK. Who is the "generator." Case 1. If the railroad or truck line were transporting a "hazardous waste" that ABCo. made in its plant, ABCo would be responsible for all aspects of the transportation, storage, and final disposal, period. So if the trucking company spilled the waste, and trucking company went bankrupt, ABCo would have to pay for everything, even if the spill were 100% the fault of the trucking company or a third party. Now after they pay the bill, ABCo. could sue the trucking company or third party and try to get their money back, but that would be a separate issue. Case 2. The railroad or trucking line is shipping a useful chemical from DowChem. The truck runs off the road, tips over and spills the chemical. Now the cleaned up chemical is contaminated with dirt and dead birds, etc. and it is now a hazardous waste. Who is the "generator" of the waste? It is probably the trucking company or perhaps the contractor that picked up the spilled gunk and put it in barrels to dispose, not DowChem. As a practical matter, the transporters are heavily insured, and the insurance company will be financially responsible.

**Q. How would it be determined for a mixture of wastes?
A. Ouch. I went to a three day course in "manifesting hazardous waste," and I guarantee this is a complex, nit-picking subject. You might characterize the mixture by its most toxic or troublesome or predominant component. There are also some generic classifications "n.o.s." which stands for "not otherwise specified" that might fit. Don't try this at home, get a hazmat expert.

** Q. I found it somewhat confusing that the ERG book did not list any of the chemicals from our homework in the TIH section. Yet the descriptions of virtually all stated that the substances were toxic if inhaled. I guess I'm not clear on what criteria puts something into the TIH category.
A. It is a liquid or a gas which is known to be so toxic to humans as to pose a hazard to health during
transportation, or in the absence of adequate data on human toxicity, is presumed to be toxic to
humans because when tested on laboratory animals it has an LC50 value of not more than 5000 ppm.

*Q. The one thing I found interesting was how many items are not covered by TIH evacuation requirements.
A. Many things are not volatile.

*Q. I did not understand the responsibilities of different agencies regarding the transportation of hazardous materials. I hadn't thought about which organization was responsible for the truck driver, etc.
A. Three different federal agencies with slightly overlapping responsibilities. Actually, they seem to cooperate pretty well about this, probably because DOT has a long history of dealing with hazardous material transport.

*Q. I'm still a bit unclear about the manifest. Is one specific form that is given out by an agency (DOT?), or is it just required information that must be on the shipping documentation?
A. I believe the exact form could vary a bit, but there are very specific requirements for the information that must be there and there is a standard EPA form, so everyone uses that. Here's a copy http://www.erefdn.org/educationact2/8700-22.pdf

*Q. It wasn't clear to me whether or not you could actually have 2 hazard classes or division numbers for a particular chemical. If you were transporting something that did have 2 or more different hazard classes, I assuming you'd use 2 different placards.
A. Each chemical or waste should have only one class. Some trucks, however, are built to carry several chemicals in one load. In that case, you would use the highest hazard class, and would need more than one placard.

* Q. It seems funny to me that gasoline and benzene, a component of gasoline, are individually in the guide.
A. The benzene content of gasoline is quite varied. Benzene is also a useful chemical by itself and often transported and used by itself.

*Q. On the quiz, #10 [8] mentions that any 'logical and competent' manifest may NOT be used to track the shipment of waste in the U.S. This confuses me because if a manifest is generated and all of the representing parties have to sign the document, i.e. transport companies, etc., then how wouldn't one be able to track the shipment of the waste?
A. Just wanted to emphasize the nit picking. You need to use the standard forms, you cannot roll your own.

* Q. What I find amazing is how complicated DOT placarding seems. Incompatible materials have the same designation, and depending on the quantities of materials being shipped, there could be a truck full of material with one generic placard. This seems outdated, too complex, and misleading to responders.
A. The placard is to help the emergency responders. There are 30,000 chemicals in common commercial use. One size will not fit all. Someday, perhaps soon, each truck will have a barcode, and all such movements can be tracked realtime. For now, the take-home message is that things like placards are needed and must be properly displayed or the owner (shipper) and the carrier may be in big trouble.

*Q. One thing I found foggy was an easy way to tell a chemical's hazard class number from the ERG.
A. This is set by the DOT regulations. You can see an extract of them on Table 10.2, page 197 of your book. Or you could root around in 49 CFR 173 and find them for each chemical. Book is easier

*Q. I could not understand completely the regulations for the placard. The label in the pictures contents a lot of information, but the labeling that DOT requires is very short. Are two different labels required, DOT and Hazcomm labels?
A. Yes, both the diamond with the hazard class and the placard identification number must be shown. They can be combined into a diamond with the number, but usually the number is separate.

* Q. You state, "The Reportable Quantity of all materials must be determined. This is the amount of material that, if spilled, must be reported to the national response center. That's in 49 CFR 172 Table 1." I looked in Table 1 of 49 CFR 172 and didn't see anything about "reportable quantity". What column is that in?
A. You got me going there. The "Table" that I abstracted in the module is in the regulation, 49 CFR 172.101, Hazardous Material Table. A little further in the regulations is 49 CFR 172, Table 1. There you will find DOT's list of Reportable Quantities. A similar list is found in the EPA regulations, 40 CFR 302, Table 304.2.

*Q. The spill in Kansas seemed to be handled quite impulsively. The nitric acid information I found said that the containers should not be allowed to get water inside of them. This allows for the nitric acid to heat up and further increases the amount of vapor in the air. It also allows for the transportation of the burning chemical. I know that they followed the regulations on evacuation areas, but did the water help the situation? Or did it help to get rid of the acid by allowing it to react with the water and vaporize (or burn)? Another question, did the pilots of the helicopter wear the SCBA PPE that was recommended. I'm sure they may have experienced some overexposure.
A. I think it is pretty rare for pilots to wear PPE. Emergency pilots and fire fighters sometimes feel challenged to take a chance to "save a life." In fact for many emergency situations, averaged over the years, there is greater death toll for the would-be rescuers than the original victims. It is important for those types of "emergency responders" to have clear "rules of engagement" that makes clear that beyond certain limits, they are being foolish, not brave. Often in emergency responses, the question is, "What happened?" Later we know its nitric acid. At the time, it may be unknown. One reason for the requirement for large placards is that the responder can read them from a distance.