Are Conditionally Exempt Small Quantity Generators required to be DOT trained?
Yes, if the CESQG meets the definition of a hazmat employee, “a person who affects hazardous material transportation safety.” Though CESQG waste is exempt from manifest requirements, hazardous material transportation regulations continue to apply. Therefore if the CESQG is preparing the material for shipment, signing bill of ladings for shipments, and/or is affecting transportation safety in any way, DOT training is required. Reference: 49 CFR 172 Subpart H.
Related Questions
- What are large quantity generators (LQG), small quantity generators (SQG) and conditionally exempt small quantity generators (CESQGs)?
- How do I know if I am a Conditionally Exempt Small Quantity Generator (CE-SQG) or a regulated generator?
- Are Conditionally Exempt Small Quantity Generators required to be DOT trained?
