HAZARDOUS WASTE CLASS 1 EXPLOSIVES: STORAGE AND TRANSPORTING GUIDELINES

Federal rules about the storage and transport of Class 1 explosives are proliferated by at least three different agencies: the EPA ,the DOT, and the ATF¹.
(¹Bureau of Alcohol, Tobacco, Firearms, and Explosives)

So what’s to know?

Class 1 Hazardous Waste Explosives are any substances, articles, or devices that explode—either intentionally or by accident. Each is subcategorized into one of six divisions based upon the relative degree of danger it poses and the predominate kind of hazard it presents: destructive shockwave, fire hazard, and/or projectile emission.

The first three categories are the biggest and baddest:

1.1 Mass explosion hazards. Prime examples are rocket fuel and dynamite, each notorious because even a small spark will cause it to explode instantly with destructive force, ruining your whole day and especially that of anyone nearby. Other examples are nitroglycerine, mercury fulminate (used in blasting caps), and certain kinds of fireworks.

CAUTION!

Hazardous Waste Experts prepared this blog as a first step to familiarize you with the many requirements of storing and transporting Class 1 Explosives. It should not be used as a substitute for reading and understanding current federal and state rules and requirements. As in all things concerning hazardous waste management—expert advice is crucial—and the lack of it is dangerous.

1.2 Projection hazards. These explosives are dangerous not only because they go boom in a big way—they also can emit shrapnel and/or other dangerous projectiles with explosive force. Obvious constituents of this category are most forms of ammunition and grenades, as well as some types of detonating fuses—should you be in charge of a small arsenal.

1.3 Fire hazards. Pyrotechnic flash powders for fireworks are a common example here, as well as some liquid and solid propellants, because in addition to other environmental peccadillos, they’re a fire hazard. Another seemingly benign example is sodium picramate, used in hair dye to produce color inside hair fiber rather than just on top. Oh, and some rocket motors.

The remaining four categories are only robust enough for minor disasters and conflagrations, thus deemed not as dangerous. These include:

1.4 Package-confined hazards. These culprits can explode, typically during transport, but the blasts are mostly confined to their packaging, presenting a relatively smaller hazard than categories 1 thru 3. Examples are signal flares and stress signals, ammo tracers, weapon cartridges, and (of course) certain kinds of fireworks.

1.5 Insensitive-substance hazards. This category is mostly occupied by blasting agents concocted of pelleted ammonium nitrate in combination with fuel oil. They can explode, but you have to try really hard.

1.6 Extremely insensitive-substance hazard. Even more benign than their Category 1.5 counterparts, these are substances—usually detonating devices—that exhibit little probability of ignition in storage or transport. Maybe your favorite chili sauce might fall into this catagory?

Transportation requirements for Class 1 hazmat explosives

The transportation of Class 1 hazmat explosives is closely regulated, especially for materials in the 1.1 thru 1.3 categories, which are the most dangerous to life, limb, and treasure.

For starters, your truck drivers are required to have paperwork that’s easily assessable to all interested parties. These include written emergency instructions, and a route prepared in advance of movement. A copy of Federal Motor Carrier Safety Regulations Part 397 should also be onboard for leisure reading, which covers pertinent driving and parking rules.

Among those pertinent driving and parking rules, Class 1 loads are severely restricted from some US tunnels and bridges—if not completely verboten. Parked vehicles with Class 1 loads must be attended to at all times and cannot be within 300 feet of a bridge, tunnel, crowded place, or fire—the last of which, we think, should be rather intuitive. But not to digress…

There’s the issue of labeling:

Labels are always diamond-shape; and their size must adhere to international standards, measuring at least 4″ x 4″ (100 mm) on each side, square-on-point. There are seven different flavors of Class 1 Explosives labels.

First up is plain vanilla, which merely reads “EXPLOSIVES 1.” The rest conform to the six subcategories: “EXPLOSIVES 1.1,” “EXPLOSIVES 1.2”, “EXPLOSIVES 1.3,” and so on, which curious civilians will undoubtedly google as they tailgate the truck, posing its own ironic hazard.

And there’s also the issue of compatibility:

Some substances that are relatively benign in isolation become predisposed to violence when close to one another. E.g., copper sulfide and cadmium chlorate explode in close proximity. So you don’t want to load a few tons of each on the back of a semi. Ditto for hydrogen peroxide and iron sulfide, which don’t cotton to being together up-close and personal.

Something else to consider—chemical groups react with other groups. For example, oxidizers, (of course) give off oxygen, making the ambient air more supportive of combustion. Thus, loading flammable materials nearby is asking for trouble. And you don’t want trouble.

As we’re fond of reminding our readers, you should get expert advice before proceeding.

Storage requirements for Class 1 hazmat explosives

Rules for storing explosives are mostly written and enforced by the ATF, which you can consider in detail here. Therein, you’ll be further directed to federal explosives regulations at 27 CFR, Part 555, Subpart K. It provides specific construction requirements for your “explosives magazine,” which is the place wherein ammo or other explosives must be stored.

All that said, it behooves us to call your attention again to the not-so-fine print in the box to your right. But ever onward…

There are five kinds of magazines:

• Type 1 are permanent structures
• Type 2 are mobile and portable structures
• Type 3 are portable structures for temporary storage (“day boxes”)
• Type 4 are for “low explosives,” which tend to burn but not explode per se
• Type 5 are reserved for the storage of blasting agents

All explosive materials must be kept in locked magazines meeting the standards mandated in Subpart K unless they are quote:

• In the process of manufacture
• Being physically handled in the operating process of a licensee or user
• Being used
• Being transported to a place of storage or use by licensee or permittee or by a person who has lawfully acquired explosive materials under Sec.555.106

Other requirements for magazines include but aren’t limited to:

• They must be sited at specified minimum distances from inhabited buildings, public highways, passenger railways, and other magazines
• They must be inspected every 7 days
• Permanent outdoor magazines must have a substantial foundation or be metal skirted to prevent access underneath the magazine
• Explosive materials may not be left unattended in Type-3 magazines, including “day boxes,” and must be removed to type 1 or 2 magazines for unattended storage

The upshot

No surprise. The EPA isn’t amused by large explosions. Neither is the DOT. Nor the ATF. If people get hurt, there will be the consequent media circus. And local, state, and federal prosecutors will be competing among themselves to indict you on a boatload of charges, likely to include criminal negligence. And as to involuntary manslaughter—let’s not go there.

Get Expert Advice

In sum, as in all things regarding hazardous waste, it’s crucial to get expert advice. And even more so when it comes to things that explode. Hazardous Waste Experts prepared this blog as a first step to familiarize you with the many requirements of storing and transporting Class 1 Explosives. It should not be used as a substitute for reading and understanding current federal and state rules and requirements. As in all things concerning hazardous waste management—expert advice is crucial.

For expert advice call Hazardous Waste Experts at (425) 414-3485.