Product Storage, Transportation and Distribution
Moving a product from the site of manufacture or import to the customer requires compliance with regulatory requirements. Beveridge & Diamond has considerable experience with U.S. Department of Transportation regulations and other applicable authorities as they apply to the storage, transportation, and distribution of products. (Reverse distribution is covered under “Recalls, Returns & Reverse Distribution.”) Among other things, we have helped clients with the following.
- All aspects of compliance with the regulations for the domestic and international transport of hazardous materials and dangerous goods, including the requirements for classifying materials, packaging, marking, labeling, placarding, shipping papers, emergency response information, security planning, registration, and training.
- Preparation of compliance programs for transportation regulations, such as:
- Helping a nationwide retailer prepare a personnel training program, a security plan, and a system for ensuring that its numerous shipments with varying combinations and amounts of products either qualify for exceptions or satisfy applicable regulatory requirements.
- Working with the compliance officers of a major overnight transport company to ensure that its compliance plans meet Transportation Security Administration requirement
- Defense of clients in the trucking, cargo airline, manufacturing, and consumer retailing sectors against actions under the Hazardous Materials Regulations brought by the Federal Aviation Administration, the Federal Motor Carrier Safety Administration, and U.S. Customs and Border Protection.
- Petition to the Department of Transportation for a special permit to streamline the Hazardous Materials Regulations for a family of electric products with multiple hazards, varying quantities of hazardous materials, and a range of different packaging arrangements.
- Regulatory requirements applicable to wastes generated at a third-party warehouse due to spills or product contamination or expiration, as well as the responsibilities of various parties for properly managing such wastes.
- Defense of an Environmental Protection Agency enforcement action alleging that products left unused for several years should have been stored in accordance with hazardous waste regulatory requirements under the Resource Conservation and Recovery Act.
- Moving unregistered pesticides from site to site for manufacturing purposes.