DOT defines pre-transportation functions as any function performed by any person that is required to assure the safe transportation of a hazardous material in commerce. When performed by shipper personnel, this includes loading of packaged or containerized hazardous material onto a transport vehicle, aircraft or vessel and filling a bulk packaging with hazardous material in the absence of a carrier for the purpose of transporting it.
Warehouse operators and carriers should pay close attention to "Storage incidental to movement." According to DOT the definition is storage by any person of a transport vehicle, freight container or package containing a hazardous material between the times that a carrier takes physical possession of the hazardous material for the purpose of transporting it until the package containing the hazardous material is physically delivered to the destination indicated on a shipping document. The final rule was intended to clarify the applicability of the Hazardous Materials Regulations to specific functions and activities.— Gene Sopchak, Asst. V.P. Regulatory Compliance, Panalpina Houston