On March 25, 2016, the United States Department of Transportation announced a new series of regulations covering “reverse logistics.” These new regulations are aimed at addressing the return transportation of hazardous materials. Under the new regulations, reverse logistics is now defined as “the process of offering for transport or transporting by motor vehicle goods from a retail store for return to its manufacturer, supplier or distribution facility for the purpose of capturing value — e.g. to receive manufacturer’s credit — recall, replacement, recycling or similar reason.” The DOT was alerted by various non-profit associations about the blind spot in hazardous waste transportation almost a decade ago, and these new regulations are the result of efforts to address the problem. The agency released a statement, saying in part “[i]n order to reduce undeclared, misdeclared or improperly packaged hazmat from being offered and transported in commerce, we are amending the HMR to better address the reverse logistics supply chain.” “Specifically, we are seeking to ensure retail employers properly identify hazardous materials in the reverse logistics chain and ensure that their employees have clear instructions to safely offer such shipments.” Included in the new regulations are specific rules relating to things such as package sizes and battery shipments.
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