Retailers Get Help With New DOT “Reverse Logistics” Rules
The U.S. Department of Transportation has finalized new shipping requirements aimed at retail stores that return hazmat products to a supplier or manufacturer for a refund.
Because the hazmat products found in retail stores typically pose little risk to the public in small amounts, U.S. DOT has created a streamlined, simplified version of the hazmat rules for retail stores that prepare reverse logistics or “return-to-vendor” (RTV) shipments.
The reverse logistics hazmat rule became effective immediately upon publication on March 31, 2016, making it critical that retail store owners and distribution managers get up to speed quickly.
As DOT defines it, “reverse logistics” means the process of shipping products from a retail store to a manufacturer, supplier, or distributor for the purpose of replacement, recycling, recall, or getting a refund or credit. As part of the rule, retailers must train employees who prepare reverse logistics shipments on the new requirements. [49 CFR 173.157(e)] The new standards also include quantity limitations, packaging requirements, marking and labeling rules, and more for these retail hazmat shipments.
Products on retail shelves that meet DOT’s definition of a hazardous material include:
- Cleaning supplies (bleach, ammonia)
- Paint, paint thinners, lacquers, etc.
- Most aerosol cans
- Chlorine tablets
- Butane lighters
- Car batteries
The new reverse logistics rules will apply to motor vehicle shipments offered for transport by private carriers only. Not all hazmat products are eligible for relief under the relaxed standards, so it’s important that retail professionals know how to identify which are which. Hazardous wastes generated by retail facilities, for example, are not covered under reverse logistics.
Batteries Not Included (Lithium Batteries, That Is)
Notably not included in DOT’s new reverse logistics hazmat rule are lithium batteries. Because of the unique hazards associated with these batteries in transport, these shipments must be prepared under other specific U.S. DOT regulations, found at 49 CFR 173.185. Those requirements apply to batteries shipped alone, with equipment, or in equipment.
The rules for lithium batteries have changed significantly in recent years, with both U.S. and international regulations creating new rules for ground, air, and ocean shipments.
With fines for hazmat shipping mistakes as high as $75,000 per day, per violation, it’s critical that retailers learn the new rules and incorporate the requirements into their standard operating procedures as soon as possible.