QUESTION:
I was wondering where I can find the most current information regarding shipping paper requirements for pest control technicians. I have tried to navigate through the D.O.T. website and the PHMSA website, but the info I find seems to be for vehicles transporting pallets of product, not just a gallon or two. I am aware of fumigant requirements, but items like gasoline, aerosols, etc. are my gray area. Any help you can provide would be greatly appreciated!
ANSWER:
A bit of history here, and I may be slightly off on the dates, but somewhere in the mid-1990’s DOT chose to define all pesticides as “hazardous materials”, and to require pest control companies to place DOT labels on spray tanks for many products and to carry shipping papers for many products. This had to do, in great part, with the quantities of the pesticide active ingredients “on board” a vehicle. At that time many of our most commonly used products were organophosphates like diazinon and chlorpyrifos, and carrying a single pound of active ingredient on the vehicle or in a spray tank triggered the requirement for Shipping Papers. It also triggered the requirement for specific DOT training for each employee who operated a vehicle with this “reportable quantities” (RQ) of the active ingredient on the vehicle.
Then, just a couple of years after this rather heavy regulation hit our industry the NPMA (National Pest Management Association) worked closely with DOT and managed to come to some compromises that backed us out of most of the DOT responsibilities. Our industry now carries what DOT refers to as “Materials of Trade” products, and you can visit the DOT website on this at
https://www.dot.ny.gov/divisions/operating/osss/truck/carrier/materials-of-trade . This placed the quantity of any active ingredient at a very high level before it would trigger a need to placard, train, or carry shipping papers. In addition, the loss of nearly all of the organophosphates removed the most troublesome of the pesticides we carried, and the RQ for groups like the Pyrethroids is about 1000 lbs of the active ingredient, a quantity no pest control vehicle will ever carry.
I am confident that the gasoline in the vehicle’s tank is not considered part of the MOT transport, but only gasoline carried in separate containers for use for sprayer engines, mowers, etc. For all of the other MOT products you carry the amount you must stay under is a combined 440 lbs of product. NOT included in this weight limit is a spray tank with material mixed with water, up to a 400 gallon tank. Since a single gallon of liquid weighs about 9 lbs you would have to be transporting nearly 50 gallons of pesticides or other MOT’s to reach the limit at which shipping papers might be required. This is highly unlikely for the vast majority of pest control and landscape vehicles, and the reason DOT allowed us to slip off their radar.
However, basic DOT training is still required so that drivers of vehicles that do carry hazardous materials are aware of what the requirements are, what the products of interest are, and how they must be packaged (gas in an appropriately marked gas container for example, pesticides in appropriate containers that are properly labeled, etc. ) Check out that website link above and if it doesn’t work for you try the search words “D.O.T. Materials of Trade Pesticides” and see if you get the proper hit.
For fumigants little has changed, as these are in the highest level of hazard and still require shipping papers and placarding. For all other normal uses and transport of minor quantities there should be nothing you need to do out of the ordinary, which is to properly store and label everything on the vehicle and carry it in secure storage that can be locked. You also should carry the Label and MSDS for each product on the vehicle, as these documents contain emergency information in case of a spill or other problem. Gasoline refers only to extra containers and the quantities you carry would be very low.
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