AMIA 2005, Austin
NITRATE FILM
TRANSPORTATION
REGULATIONS
Rosa Gaiarsa
Collection Services Manager
UCLA Film & Television Archive
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 Council’s
Committee of Experts on the Transport of Dangerous Goods
http://www.unece.org/trans/danger/publi/unrec/rev14/14files_e.html
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
US - Regulatory history
1975 – Transportation Safety Act

Established the National Transportation Safety
Board as an independent agency and
authorized the Secretary to…regulate the
transportation of all hazardous materials, and
to impose both civil and criminal penalties for
violations of those regulations
US - Regulatory evolution

1977 – Transportation Safety Institute and
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2004 – RSPA reorganized into Pipeline and
other agencies are consolidated into the
Research and Special Programs
Administration, RSPA
Hazardous Materials Safety Administration,
PHMSA
http://hazmat.dot.gov/
US - Regulatory Code
All modes of transportation of
dangerous goods are regulated by
the Department of Transportation’s
Code of Federal Regulations, CFR49
http://www.myregs.com/dotrspa
Four Modal Regulations
 Highway
 Rail
 Water
 Air
International regulations - Air

ICAO: International Civil Aviation Organization’s
Standards and Recommended Practices –
Technical Instructions for the Safe Transport of
Dangerous Goods by Air
http://www.icao.int

IATA: International Air Transport Association’s
Dangerous Goods Regulations (more restrictive
than ICAO – updated annually)
http://www.iata.org
Basic shipment requirements
Classification
 Identification
 Packaging
 Marking and labeling
 Documentation
 Training
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Classification – UN criteria
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Class
Class
Class
Class
Class
Class
Class
Class
Class
1
2
3
4
5
6
7
8
9
–
–
–
–
–
–
–
–
–
Explosives
Gases
Flammable liquids
Flammable solids
Oxidizing Substances
Toxic and infectious substances
Radioactive material
Corrosives
Miscellaneous DG
Class 4 subdivision
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4.1 Flammable solids
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4.2 Substances liable to
spontaneous combustion
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4.3 Substances which, in contact
with water, emit flammable gases
(dangerous when wet)
Identification / Packing group
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Proper shipping name
Films, nitrocellulose base
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UN / ID
UN1324
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Packing group
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Group I (X): high danger
Group II (Y): medium danger (IATA)
Group III (Z): low danger (CFR)
UN certified outer package
Example:
Fiberboard box
UN 4G
Buyers beware: request
copy of test report from
manufacturer and/or
supplier of packaging
materials
Packaging types
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Inner package: film can or box
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Outer package: list of fourteen
containers that are tested and
certified by UN specifications
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Overpack: to bundle outer packages
for shipment
Packing instructions IATA
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Y400
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Limited quantities:
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1 kg per inner package
10 kg (22 lbs) net weight
400
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Passenger and cargo aircraft:
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25 kg (55 lbs)
Cargo aircraft only:
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100 kg (220 lbs)
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
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Vehicles transporting more
than 1001 lbs (454 kg) of
nitrate film have to be
placarded
It’s 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
Documentation
Shipper’s 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
Emergency phone / requirements
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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
Emergency phone / options
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The telephone number must be the
number of the person offering the
hazardous material for transportation or
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The number of an agency or organization
capable and responsible for providing
detailed information concerning the
hazardous material
Emergency phone / service providers
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US
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Chemtrec
Chem-tel
Infotrac
3E Company
 Canada
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Canutec
http://hazmat.dot.gov/pubs/erg/erg2004.pdf
Hazmat Training
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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)
Training content
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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)
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
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http://hazmat.dot.gov/training/training.htm
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)
Materials of trade regulations
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Less restrictive packaging
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Less restrictive marking and labeling
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Limit of 30 kg (66 lbs) per package
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Aggregate gross weight may not
exceed 200 kg (440 lbs)
Better safe than sorry
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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
AMIA 2005, Austin
NITRATE FILM
DISPOSAL
REGULATIONS
Rosa Gaiarsa
Collection Services Manager
UCLA Film & Television Archive
US - Regulatory history

1965 – Solid Waste Disposal Act was signed
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1970 – Environmental Protection Agency was
created
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1976 – Resource Conservation and Recovery Act
was signed
http://www.epa.gov/epaoswer/general/k02027.pdf
US – Regulatory code
1980: RCRA published the Hazardous Waste and
Consolidated Permit Regulations
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Tracking and permitting to monitor and control
hazardous waste
Strict requirements for storage, treatment and
disposal of hazardous waste
Authorized States to implement RCRA’s waste
management program
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/romtoc.pdf
Hazardous Waste identification
Listed
 Characteristics
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Ignitable
 Corrosive
 Reactive
 Toxic
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Waste generator classifications
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Large quantity generator (LQG)
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Small quantity generator (SQG)
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1000 kg (2200 lbs) or more of hazardous waste
per month
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
State regulations*
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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
Requirements for SQGs
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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
Accumulation and storage requirements
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CESQGs cannot accumulate more than 1,000 kg
(2200 lbs = +/- 450 x 1000ft cans) of
hazardous waste on site at any time
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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
Preparation for shipment – 49CFR
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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:
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Limited quantities: 173.151
Non-bulk: 173.212
Selecting Transporter and TSDF
(Treatment, Storage and Disposal Facility)
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Your institution’s Hazmat Office
Local references
Trade associations
Better Business Bureau
City, County or State Hazmat
Management Agency
Regional EPA Office
Manifest*
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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
Enforcement
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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
EPA contact information
Links to State web pages and
EPA regional web pages
http://www.epa.gov/epaoswer/osw/comments.htm