NITRATE FILM

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NITRATE FILM
AMIA 2005, Austin

• TRANSPORTATION REGULATIONS

Rosa Gaiarsa Collection Services Manager UCLA
Film Television Archive
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First transportation guidelines

• First version of Recommendations on the Transport
  of Dangerous Goods, RTDG, published in 1956 by
  the UN

United Nations Economic and Social Councils
Committee of Experts on the Transport of
Dangerous Goods http//www.unece.org/trans/danger/
publi/unrec/rev14/14files_e.html
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UN Recommendations (RTDG)

• The document is regularly amended to align with
  new technologies and changing needs of users
• The document itself has no legal force except
  when adopted in agreements and/or domestic
  legislation

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US - Regulatory history

• 1975 Transportation Safety Act
• Established the National Transportation Safety
  Board as an independent agency and authorized the
  Secretary toregulate the transportation of all
  hazardous materials, and to impose both civil and
  criminal penalties for violations of those
  regulations

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US - Regulatory evolution

• 1977 Transportation Safety Institute and other
  agencies are consolidated into the Research and
  Special Programs Administration, RSPA
• 2004 RSPA reorganized into Pipeline and
  Hazardous Materials Safety Administration, PHMSA

http//hazmat.dot.gov/
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US - Regulatory Code

• All modes of transportation of dangerous goods
  are regulated by the Department of
  Transportations Code of Federal Regulations,
  CFR49

http//www.myregs.com/dotrspa
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Four Modal Regulations

• Highway
• Rail
• Water
• Air

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International regulations - Air

• ICAO International Civil Aviation Organizations
  Standards and Recommended Practices Technical
  Instructions for the Safe Transport of Dangerous
  Goods by Air
• http//www.icao.int
• IATA International Air Transport Associations
  Dangerous Goods Regulations (more restrictive
  than ICAO updated annually)
• http//www.iata.org

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Basic shipment requirements

• Classification
• Identification
• Packaging
• Marking and labeling
• Documentation
• Training

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Classification UN criteria

• Class 1 Explosives
• Class 2 Gases
• Class 3 Flammable liquids
• Class 4 Flammable solids
• Class 5 Oxidizing Substances
• Class 6 Toxic and infectious substances
• Class 7 Radioactive material
• Class 8 Corrosives
• Class 9 Miscellaneous DG

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Class 4 subdivision

• 4.1 Flammable solids
• 4.2 Substances liable to spontaneous combustion
• 4.3 Substances which, in contact with water, emit
  flammable gases (dangerous when wet)

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Identification / Packing group

• Proper shipping name
• Films, nitrocellulose base
• UN / ID
• UN1324
• Packing group
• Group I (X) high danger
• Group II (Y) medium danger (IATA)
• Group III (Z) low danger (CFR)

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UN certified outer package

• Example
• Fiberboard box
• UN 4G

Buyers beware request copy of test report from
manufacturer and/or supplier of packaging
materials
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Packaging types

• Inner package film can or box
• Outer package list of fourteen containers that
  are tested and certified by UN specifications
• Overpack to bundle outer packages for shipment

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Packing instructions IATA

• Y400
• Limited quantities
• 1 kg per inner package
• 10 kg (22 lbs) net weight
• 400
• Passenger and cargo aircraft
• 25 kg (55 lbs)
• Cargo aircraft only
• 100 kg (220 lbs)

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Marking and labeling

• Shipment label shipper and consignee info
• Hazard label
• Proper shipping name
• UN/ID number
• Multiple packages ID mark on overpack
• Net quantity info in kg
• Overpack notice
• Air eligibility label

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Placarding CFR49

• Vehicles transporting more than 1001 lbs (454 kg)
  of nitrate film have to be placarded
• Its the responsibility of the shipper to provide
  the proper placards to the carrier
• If you offer for shipment an amount of nitrate
  film that requires placarding, registration with
  the DOT is required

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Documentation

• Shippers Declaration of Dangerous Goods
• Two copies required by law, but some carriers
  require three copies
• Papers have to be retained for 375 days after the
  material is accepted by the initial carrier

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Emergency telephone number

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

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Emergency phone / requirements

• Person must be knowledgeable of the hazardous
  material being shipped
• Person must have comprehensive emergency response
  and incident mitigation information for the
  material
• Phone must be monitored at all times, 24/7
• Answering service, answering machine, or beeper
  devices are not accepted

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Emergency phone / options

• The telephone number must be the number of the
  person offering the hazardous material for
  transportation or
• The number of an agency or organization capable
  and responsible for providing detailed
  information concerning the hazardous material

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Emergency phone / service providers

• US
• Chemtrec
• Chem-tel
• Infotrac
• 3E Company

• Canada
• Canutec

http//hazmat.dot.gov/pubs/erg/erg2004.pdf
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Hazmat Training

• Employer is responsible for compliance with
  training requirements
• Training may be provided by the employer or
  other public or private sources
• Employee has to be trained within 90 days of
  employment
• Employee has to be re-trained every 24 months
  (IATA)

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Training content

• General awareness
• Function-specific training
• Safety training
• Awareness training of transportation security
  risk (CFR, added in 2003)
• In-depth training of security plan (CFR, added in
  2003)

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Testing and documentation

• After training, Hazmat employee has to be tested
  and provided with a certificate of training
  completion
• Training records have to be kept and made
  available to enforcement agents upon demand

http//hazmat.dot.gov/training/training.htm
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CFR49 / Materials of trade exception

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

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Materials of trade regulations

• Less restrictive packaging
• Less restrictive marking and labeling
• Limit of 30 kg (66 lbs) per package
• Aggregate gross weight may not exceed 200 kg (440
  lbs)

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Better safe than sorry

• Any violation of a requirement of the Federal
  hazardous material transportation law is liable
  for a civil penalty of not more than 32,500 and
  not less than 275 for each violation
• Federal law forbids the carriage of hazardous
  materials aboard aircraft in your luggage or on
  your person. A violation can result in five
  years' imprisonment and penalties of 250,000 or
  more

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NITRATE FILM
AMIA 2005, Austin

• DISPOSAL
• REGULATIONS

Rosa Gaiarsa Collection Services Manager UCLA
Film Television Archive
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US - Regulatory history

• 1965 Solid Waste Disposal Act was signed
• 1970 Environmental Protection Agency was
  created
• 1976 Resource Conservation and Recovery Act was
  signed

http//www.epa.gov/epaoswer/general/k02027.pdf
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US Regulatory code
1980 RCRA published the Hazardous Waste and
Consolidated Permit Regulations

• Tracking and permitting to monitor and control
  hazardous waste
• Strict requirements for storage, treatment and
  disposal of hazardous waste
• Authorized States to implement RCRAs waste
  management program

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Regulatory amendment
1984 - Hazardous and Solid Waste Amendments

• Regulated businesses that generated even small
  amounts of hazardous waste

http//www.epa.gov/epaoswer/general/orientat/romto
c.pdf
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Hazardous Waste identification

• Listed
• Characteristics
• Ignitable
• Corrosive
• Reactive
• Toxic

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Waste generator classifications

• Large quantity generator (LQG)
• 1000 kg (2200 lbs) or more of hazardous waste per
  month
• Small quantity generator (SQG)
• More than 100 kg (220 lbs) but less than 1000 kg
  per month
• Conditionally exempt small quantity generator
  (CESQG)
• Less than 100 kg (/- 45x1000ft cans) per month

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State regulations

• State regulations may be more strict than Federal
  requirements
• Some States require CESQGs to follow some of the
  SQGs requirements

Generators need to contact their respective
state agency to determine if state regulation
differs from federal requirements
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Requirements for SQGs

• Obtain an EPA identification number from your
  State Environmental Office
• Comply with accumulation and storage requirements
  
• Comply with requirements for training,
  contingency planning and emergency response
• Prepare the waste for shipment (packaging,
  labeling, marking, placarding)
• Comply with the manifest system
• Meet record keeping and reporting requirements

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Accumulation and storage requirements

• CESQGs cannot accumulate more than 1,000 kg (2200
  lbs /- 450 x 1000ft cans) of hazardous waste
  on site at any time
• SQGs can accumulate no more than 6,000 kg (13,228
  lbs) on site for up to 180 days without a permit

http//www.epa.gov/epaoswer/hazwaste/sqg/handbook/
k01005.pdf
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Preparation for shipment 49CFR

• Proper shipping name Nitrocellulose with water
  (with no less than 25 water, by mass)
• UN/ID UN 2555
• Hazard label 4.1
• Packing group II
• Packing instructions
• Limited quantities 173.151
• Non-bulk 173.212

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Selecting Transporter and TSDF
(Treatment, Storage and Disposal Facility)

• Your institutions Hazmat Office
• Local references
• Trade associations
• Better Business Bureau
• City, County or State Hazmat Management Agency
• Regional EPA Office

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Manifest

• Required by EPA and DOT
• Multiple copies as tracking tool from generator
  to transporter to disposal facility
• Records retained for three years

new form to be adopted in 2006
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Enforcement

• EPA can use administrative, civil, or criminal
  enforcement actions to address RCRA violations
• Penalty amounts are case specific
• Penalty is calculated on base amount and a
  multi-day component
• EPA may reduce or waive penalties for violations
  that are promptly disclosed and corrected

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EPA contact information
Links to State web pages and EPA regional web
pages

• http//www.epa.gov/epaoswer/osw/comments.htm