U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
U-HAUL
EHS 138aCT | Environmental Health & Safety Certification
EHS 138aCT Questions and Answers - Complete
Solution
Current U-Haul EHS Training Standards | 100% Verified | Aligned with OSHA, EPA, DOT
Total Questions 100 (across 8 sections)
Cognitive Distribution 35% Recall / 45% Application / 20% Analysis
Question Style 70% Scenario-based / 30% Direct recall
Format 4-option multiple choice (A-D), single best answer
Regulatory Citations OSHA 29 CFR 1910 / EPA 40 CFR / DOT 49 CFR
Course U-Haul EHS 138aCT - Environmental Health & Safety Certification
Answer Key Inline with detailed rationale for each question
Instructions: Select the SINGLE BEST answer for each question. Each question includes the verified correct answer with detailed
rationale explaining why the correct option is right and why the distractors are wrong, integrating regulatory citations (OSHA 29
CFR, EPA 40 CFR, DOT 49 CFR), safety principles, environmental compliance requirements, and U-Haul EHS best practices.
Content reflects the U-Haul EHS 138aCT certification domain.
Section 1: EHS Program Fundamentals and Regulatory Framework
OSHA, EPA, DOT, & Company Policy (Q1-Q14)
Q1. The Occupational Safety and Health Act's General Duty Clause (Section 5(a)(1)) requires employers to
furnish employees a place of employment free from recognized hazards. At a U-Haul storage facility, a
regional EHS manager observes unguarded conveyor belts in the moving-truck loading bay. Under the
General Duty Clause, which statement is most accurate?
A. OSHA cannot issue a citation because there is no specific standard addressing conveyor guarding at storage
facilities
B. OSHA may issue a General Duty Clause citation if the hazard is recognized, feasible abatement exists, and
the hazard causes or is likely to cause death or serious physical harm [CORRECT]
C. The General Duty Clause applies only to construction employers, not general industry employers such as U-Haul
D. Only OSHA 29 CFR 1910 Subpart D (walking-working surfaces) applies; the General Duty Clause is reserved
for chemical hazards
Correct Answer: B
Rationale:
Page 1 | 100% Verified EHS Certification Content | 100 Total Questions
,U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
OSHA's General Duty Clause, Section 5(a)(1) of the OSH Act, is used when no specific standard applies to a recognized
hazard. Four elements must be met: (1) a hazard existed in the employer's workplace that was recognized by the
industry, (2) the hazard was likely to cause death or serious physical harm, (3) a feasible means of abatement existed,
and (4) the employer or the employer's industry recognized the hazard. Choice A is wrong because absence of a specific
standard is precisely when the General Duty Clause is invoked. Choice C is wrong - the clause applies to all employers
covered by OSHA. Choice D is wrong; the clause is not limited to chemical hazards. U-Haul EHS best practice: identify
recognized hazards during routine site self-audits before OSHA does.
Q2. An OSHA compliance officer arrives unannounced at a U-Haul regional distribution center. Under 29
CFR 1903, the employer has the right to do which of the following BEFORE the inspection begins?
A. Refuse entry and require a warrant from a federal judge before any inspection
B. Request the compliance officer's credentials, hold an opening conference, and require that a reasonable
inspection time be set, but cannot lawfully refuse entry without risking a warrant [CORRECT]
C. Demand that an attorney be present before opening the door; inspection cannot proceed until the attorney arrives
D. Refuse entry unless the inspection is in response to a formal employee complaint
Correct Answer: B
Rationale:
Under 29 CFR 1903.7-1903.8, the employer may request the compliance officer's credentials and may hold an opening
conference. Employers cannot lawfully refuse entry without risking an inspection warrant (federal court order). Choice
A is wrong - while employers may demand a warrant, refusing entry without one is not without risk. Choice C is wrong
- the employer has no right to delay the inspection indefinitely waiting for counsel. Choice D is wrong - inspections are
not limited to complaint-driven visits; programmed inspections, follow-ups, and referrals also occur. U-Haul EHS
practice: train site managers to verify credentials, contact the EHS Hotline, and conduct the opening conference
professionally.
Q3. Under OSHA 29 CFR 1910.1200, the Hazard Communication Standard, which of the following is a
required element that the employer must implement for each hazardous chemical in the workplace?
A. Maintain a list of hazardous chemicals known to be present using a product identifier cross-referenced to
the SDS [CORRECT]
B. Submit each SDS to OSHA for federal approval before employee use
C. Conduct annual industrial hygiene air monitoring for every listed chemical
D. Replace all manufacturer labels with employer-generated symbols that match U-Haul's color-coding
Correct Answer: A
Rationale:
29 CFR 1910.1200(e) and (g) require employers to maintain a list of hazardous chemicals known to be present in the
workplace, cross-referenced to the SDS, and to ensure labels and SDSs are readily accessible. Choice B is wrong - SDSs
are not submitted to OSHA for approval; the manufacturer/importer is responsible for classification and SDS
development. Choice C is wrong - air monitoring is not a HazCom requirement (though it may be required under
substance-specific standards). Choice D is wrong - employer labels must conform to GHS and may not simply replace
manufacturer labels unless they retain all required GHS elements. U-Haul EHS best practice: maintain a master
chemical inventory at each site with SDS access (paper or digital) available within 60 seconds during all shifts.
Q4. A U-Haul site supervisor discovers a 55-gallon drum of waste solvent in the maintenance shop. Under
EPA's Resource Conservation and Recovery Act (RCRA, 40 CFR 260-279), the FIRST step in determining
Page 2 | 100% Verified EHS Certification Content | 100 Total Questions
,U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
proper management is to:
A. Ship the drum to the nearest municipal landfill with a non-hazardous waste manifest
B. Determine whether the waste is a solid waste under RCRA, then determine whether it is a hazardous waste
by listing or characteristic [CORRECT]
C. Apply for a hazardous waste generator EPA ID number, then later determine whether the waste is hazardous
D. Treat the solvent on-site to evaporate volatile components before determining its regulatory status
Correct Answer: B
Rationale:
Under RCRA, the regulatory hierarchy is: (1) Is the material a solid waste (discarded material)? (2) If yes, is it a
hazardous waste - either a listed waste (F, K, P, U lists) or a characteristic waste (ignitable D001, corrosive D002,
reactive D003, toxic D004-D043)? Only after this determination can proper management, manifest, and disposal be
selected. Choice A is wrong - sending to landfill without characterization violates RCRA. Choice C is wrong - the
generator ID number is only required if waste is hazardous. Choice D is wrong - on-site evaporation is a form of
treatment/disposal that requires a permit. U-Haul EHS practice: complete a waste determination form (U-Haul Form
EHS-WD-01) for every waste stream and keep on file for at least 3 years.
Q5. Under the DOT Hazardous Materials Regulations (49 CFR 171-180), a U-Haul team member is
preparing a customer's packaged household-cleaning products for transport. Which of the following correctly
identifies the document used to communicate hazmat hazard information during transportation?
A. Safety Data Sheet (SDS)
B. Hazardous Waste Manifest (EPA Form 8700-22)
C. Shipping papers (or Hazardous Materials Shipping Paper) with proper shipping name, hazard class, ID
number, and packing group [CORRECT]
D. Chemical Inventory Form (Tier II)
Correct Answer: C
Rationale:
49 CFR 172.201 requires hazardous materials shipping papers to include: proper shipping name, hazard class/division,
ID number (UN/NA), packing group, total quantity, and emergency response telephone number. The shipping paper
must travel with the shipment and be accessible to the carrier. Choice A is wrong - SDSs are workplace hazard
communication tools, not transportation documents. Choice B is wrong - EPA Form 8700-22 is for hazardous waste
transportation under RCRA, not general hazmat shipments. Choice D is wrong - Tier II inventory is for EPCRA 312
reporting, not transportation. U-Haul EHS practice: U-Haul is a household-goods carrier; team members must refuse
customer hazmat shipments unless they meet 49 CFR exceptions for limited quantities or consumer commodity
(ORM-D) provisions.
Q6. Under EPA's Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, 40
CFR 300-373), which of the following is the established threshold quantity for reporting a release of an
extremely hazardous substance (EHS) under the Emergency Planning and Community Right-to-Know Act
(EPCRA) Section 304?
A. 1 pound (0.454 kg) for every listed extremely hazardous substance
B. The Threshold Planning Quantity (TPQ) for that specific substance, ranging from 1 to 10,000 pounds
depending on the chemical [CORRECT]
C. 10 pounds of any chemical mixture regardless of concentration
Page 3 | 100% Verified EHS Certification Content | 100 Total Questions
, U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
D. Any visible sheen on navigable waters, regardless of mass released to air or land
Correct Answer: B
Rationale:
EPCRA Section 304 reporting thresholds vary by substance. The release of an extremely hazardous substance (EHS) is
reportable if it exceeds the Threshold Planning Quantity (TPQ) listed in 40 CFR 355 Appendix A. TPQs range from as
low as 1 pound (e.g., for some nerve agents) to 10,000 pounds for less acutely toxic substances. Choice A is wrong - not
all EHSs share a single threshold. Choice C is wrong - 10 pounds is the threshold for CERCLA hazardous substance
reporting for some, not all, substances. Choice D is wrong - the visible-sheen rule (40 CFR 110) applies to oil discharges
to navigable waters under the Clean Water Act, not EPCRA. U-Haul EHS practice: any release above the TPQ requires
immediate notification of the State Emergency Response Commission (SERC), Local Emergency Planning Committee
(LEPC), and National Response Center (1-800-424-8802).
Q7. Under the Clean Air Act (42 U.S.C. 7401 et seq., 40 CFR 60-90), a U-Haul maintenance shop that
performs painting or solvent degreasing operations may be subject to which of the following regulatory
programs?
A. The National Pollutant Discharge Elimination System (NPDES) permit program
B. National Emission Standards for Hazardous Air Pollutants (NESHAPs) for source categories such as
Halogenated Solvent Cleaning [CORRECT]
C. RCRA Subtitle C hazardous waste generator standards only
D. The Toxic Substances Control Act (TSCA) Polychlorinated Biphenyl (PCB) rule only
Correct Answer: B
Rationale:
40 CFR 63 Subpart T - National Emission Standards for Hazardous Air Pollutants for Halogenated Solvent Cleaning
applies to solvent vapor degreasers using perchloroethylene, methylene chloride, trichloroethylene, and similar
compounds. NESHAPs under CAA Section 112 regulate source categories of hazardous air pollutants (HAPs). Choice
A is wrong - NPDES regulates water discharges under the Clean Water Act. Choice C is wrong - RCRA Subtitle C
governs hazardous waste, not air emissions. Choice D is wrong - TSCA PCB rules govern PCB manufacture,
processing, and disposal, not solvent cleaning. U-Haul EHS practice: any U-Haul maintenance shop using solvent
degreasers must comply with NESHAP Subpart T recordkeeping, including solvent consumption logs and emission
calculations.
Q8. A U-Haul self-storage facility is located near a navigable waterway. An aboveground storage tank (AST)
at the site holds 8,000 gallons of motor oil for truck maintenance. Under the Clean Water Act's Spill
Prevention, Control, and Countermeasure (SPCC) rule (40 CFR 112), which statement is most accurate?
A. SPCC plans are required only for facilities with total aboveground oil storage capacity greater than 1,320
gallons where a discharge could reach navigable waters [CORRECT]
B. SPCC plans are required only for facilities with underground storage tanks; aboveground tanks are exempt
C. Any facility storing any quantity of oil must prepare an SPCC plan regardless of potential to reach navigable
waters
D. SPCC plans apply only to facilities drilling for oil, not to end-user sites such as U-Haul maintenance shops
Correct Answer: A
Rationale:
40 CFR 112 requires an SPCC plan for facilities with: (1) aggregate aboveground oil storage capacity greater than 1,320
gallons in containers of 55 gallons or more, OR (2) completely buried storage capacity greater than 42,000 gallons;
Page 4 | 100% Verified EHS Certification Content | 100 Total Questions
U-HAUL
EHS 138aCT | Environmental Health & Safety Certification
EHS 138aCT Questions and Answers - Complete
Solution
Current U-Haul EHS Training Standards | 100% Verified | Aligned with OSHA, EPA, DOT
Total Questions 100 (across 8 sections)
Cognitive Distribution 35% Recall / 45% Application / 20% Analysis
Question Style 70% Scenario-based / 30% Direct recall
Format 4-option multiple choice (A-D), single best answer
Regulatory Citations OSHA 29 CFR 1910 / EPA 40 CFR / DOT 49 CFR
Course U-Haul EHS 138aCT - Environmental Health & Safety Certification
Answer Key Inline with detailed rationale for each question
Instructions: Select the SINGLE BEST answer for each question. Each question includes the verified correct answer with detailed
rationale explaining why the correct option is right and why the distractors are wrong, integrating regulatory citations (OSHA 29
CFR, EPA 40 CFR, DOT 49 CFR), safety principles, environmental compliance requirements, and U-Haul EHS best practices.
Content reflects the U-Haul EHS 138aCT certification domain.
Section 1: EHS Program Fundamentals and Regulatory Framework
OSHA, EPA, DOT, & Company Policy (Q1-Q14)
Q1. The Occupational Safety and Health Act's General Duty Clause (Section 5(a)(1)) requires employers to
furnish employees a place of employment free from recognized hazards. At a U-Haul storage facility, a
regional EHS manager observes unguarded conveyor belts in the moving-truck loading bay. Under the
General Duty Clause, which statement is most accurate?
A. OSHA cannot issue a citation because there is no specific standard addressing conveyor guarding at storage
facilities
B. OSHA may issue a General Duty Clause citation if the hazard is recognized, feasible abatement exists, and
the hazard causes or is likely to cause death or serious physical harm [CORRECT]
C. The General Duty Clause applies only to construction employers, not general industry employers such as U-Haul
D. Only OSHA 29 CFR 1910 Subpart D (walking-working surfaces) applies; the General Duty Clause is reserved
for chemical hazards
Correct Answer: B
Rationale:
Page 1 | 100% Verified EHS Certification Content | 100 Total Questions
,U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
OSHA's General Duty Clause, Section 5(a)(1) of the OSH Act, is used when no specific standard applies to a recognized
hazard. Four elements must be met: (1) a hazard existed in the employer's workplace that was recognized by the
industry, (2) the hazard was likely to cause death or serious physical harm, (3) a feasible means of abatement existed,
and (4) the employer or the employer's industry recognized the hazard. Choice A is wrong because absence of a specific
standard is precisely when the General Duty Clause is invoked. Choice C is wrong - the clause applies to all employers
covered by OSHA. Choice D is wrong; the clause is not limited to chemical hazards. U-Haul EHS best practice: identify
recognized hazards during routine site self-audits before OSHA does.
Q2. An OSHA compliance officer arrives unannounced at a U-Haul regional distribution center. Under 29
CFR 1903, the employer has the right to do which of the following BEFORE the inspection begins?
A. Refuse entry and require a warrant from a federal judge before any inspection
B. Request the compliance officer's credentials, hold an opening conference, and require that a reasonable
inspection time be set, but cannot lawfully refuse entry without risking a warrant [CORRECT]
C. Demand that an attorney be present before opening the door; inspection cannot proceed until the attorney arrives
D. Refuse entry unless the inspection is in response to a formal employee complaint
Correct Answer: B
Rationale:
Under 29 CFR 1903.7-1903.8, the employer may request the compliance officer's credentials and may hold an opening
conference. Employers cannot lawfully refuse entry without risking an inspection warrant (federal court order). Choice
A is wrong - while employers may demand a warrant, refusing entry without one is not without risk. Choice C is wrong
- the employer has no right to delay the inspection indefinitely waiting for counsel. Choice D is wrong - inspections are
not limited to complaint-driven visits; programmed inspections, follow-ups, and referrals also occur. U-Haul EHS
practice: train site managers to verify credentials, contact the EHS Hotline, and conduct the opening conference
professionally.
Q3. Under OSHA 29 CFR 1910.1200, the Hazard Communication Standard, which of the following is a
required element that the employer must implement for each hazardous chemical in the workplace?
A. Maintain a list of hazardous chemicals known to be present using a product identifier cross-referenced to
the SDS [CORRECT]
B. Submit each SDS to OSHA for federal approval before employee use
C. Conduct annual industrial hygiene air monitoring for every listed chemical
D. Replace all manufacturer labels with employer-generated symbols that match U-Haul's color-coding
Correct Answer: A
Rationale:
29 CFR 1910.1200(e) and (g) require employers to maintain a list of hazardous chemicals known to be present in the
workplace, cross-referenced to the SDS, and to ensure labels and SDSs are readily accessible. Choice B is wrong - SDSs
are not submitted to OSHA for approval; the manufacturer/importer is responsible for classification and SDS
development. Choice C is wrong - air monitoring is not a HazCom requirement (though it may be required under
substance-specific standards). Choice D is wrong - employer labels must conform to GHS and may not simply replace
manufacturer labels unless they retain all required GHS elements. U-Haul EHS best practice: maintain a master
chemical inventory at each site with SDS access (paper or digital) available within 60 seconds during all shifts.
Q4. A U-Haul site supervisor discovers a 55-gallon drum of waste solvent in the maintenance shop. Under
EPA's Resource Conservation and Recovery Act (RCRA, 40 CFR 260-279), the FIRST step in determining
Page 2 | 100% Verified EHS Certification Content | 100 Total Questions
,U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
proper management is to:
A. Ship the drum to the nearest municipal landfill with a non-hazardous waste manifest
B. Determine whether the waste is a solid waste under RCRA, then determine whether it is a hazardous waste
by listing or characteristic [CORRECT]
C. Apply for a hazardous waste generator EPA ID number, then later determine whether the waste is hazardous
D. Treat the solvent on-site to evaporate volatile components before determining its regulatory status
Correct Answer: B
Rationale:
Under RCRA, the regulatory hierarchy is: (1) Is the material a solid waste (discarded material)? (2) If yes, is it a
hazardous waste - either a listed waste (F, K, P, U lists) or a characteristic waste (ignitable D001, corrosive D002,
reactive D003, toxic D004-D043)? Only after this determination can proper management, manifest, and disposal be
selected. Choice A is wrong - sending to landfill without characterization violates RCRA. Choice C is wrong - the
generator ID number is only required if waste is hazardous. Choice D is wrong - on-site evaporation is a form of
treatment/disposal that requires a permit. U-Haul EHS practice: complete a waste determination form (U-Haul Form
EHS-WD-01) for every waste stream and keep on file for at least 3 years.
Q5. Under the DOT Hazardous Materials Regulations (49 CFR 171-180), a U-Haul team member is
preparing a customer's packaged household-cleaning products for transport. Which of the following correctly
identifies the document used to communicate hazmat hazard information during transportation?
A. Safety Data Sheet (SDS)
B. Hazardous Waste Manifest (EPA Form 8700-22)
C. Shipping papers (or Hazardous Materials Shipping Paper) with proper shipping name, hazard class, ID
number, and packing group [CORRECT]
D. Chemical Inventory Form (Tier II)
Correct Answer: C
Rationale:
49 CFR 172.201 requires hazardous materials shipping papers to include: proper shipping name, hazard class/division,
ID number (UN/NA), packing group, total quantity, and emergency response telephone number. The shipping paper
must travel with the shipment and be accessible to the carrier. Choice A is wrong - SDSs are workplace hazard
communication tools, not transportation documents. Choice B is wrong - EPA Form 8700-22 is for hazardous waste
transportation under RCRA, not general hazmat shipments. Choice D is wrong - Tier II inventory is for EPCRA 312
reporting, not transportation. U-Haul EHS practice: U-Haul is a household-goods carrier; team members must refuse
customer hazmat shipments unless they meet 49 CFR exceptions for limited quantities or consumer commodity
(ORM-D) provisions.
Q6. Under EPA's Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, 40
CFR 300-373), which of the following is the established threshold quantity for reporting a release of an
extremely hazardous substance (EHS) under the Emergency Planning and Community Right-to-Know Act
(EPCRA) Section 304?
A. 1 pound (0.454 kg) for every listed extremely hazardous substance
B. The Threshold Planning Quantity (TPQ) for that specific substance, ranging from 1 to 10,000 pounds
depending on the chemical [CORRECT]
C. 10 pounds of any chemical mixture regardless of concentration
Page 3 | 100% Verified EHS Certification Content | 100 Total Questions
, U-Haul EHS 138aCT | Environmental Health and Safety Certification Complete Solutions | Current Standards Edition
D. Any visible sheen on navigable waters, regardless of mass released to air or land
Correct Answer: B
Rationale:
EPCRA Section 304 reporting thresholds vary by substance. The release of an extremely hazardous substance (EHS) is
reportable if it exceeds the Threshold Planning Quantity (TPQ) listed in 40 CFR 355 Appendix A. TPQs range from as
low as 1 pound (e.g., for some nerve agents) to 10,000 pounds for less acutely toxic substances. Choice A is wrong - not
all EHSs share a single threshold. Choice C is wrong - 10 pounds is the threshold for CERCLA hazardous substance
reporting for some, not all, substances. Choice D is wrong - the visible-sheen rule (40 CFR 110) applies to oil discharges
to navigable waters under the Clean Water Act, not EPCRA. U-Haul EHS practice: any release above the TPQ requires
immediate notification of the State Emergency Response Commission (SERC), Local Emergency Planning Committee
(LEPC), and National Response Center (1-800-424-8802).
Q7. Under the Clean Air Act (42 U.S.C. 7401 et seq., 40 CFR 60-90), a U-Haul maintenance shop that
performs painting or solvent degreasing operations may be subject to which of the following regulatory
programs?
A. The National Pollutant Discharge Elimination System (NPDES) permit program
B. National Emission Standards for Hazardous Air Pollutants (NESHAPs) for source categories such as
Halogenated Solvent Cleaning [CORRECT]
C. RCRA Subtitle C hazardous waste generator standards only
D. The Toxic Substances Control Act (TSCA) Polychlorinated Biphenyl (PCB) rule only
Correct Answer: B
Rationale:
40 CFR 63 Subpart T - National Emission Standards for Hazardous Air Pollutants for Halogenated Solvent Cleaning
applies to solvent vapor degreasers using perchloroethylene, methylene chloride, trichloroethylene, and similar
compounds. NESHAPs under CAA Section 112 regulate source categories of hazardous air pollutants (HAPs). Choice
A is wrong - NPDES regulates water discharges under the Clean Water Act. Choice C is wrong - RCRA Subtitle C
governs hazardous waste, not air emissions. Choice D is wrong - TSCA PCB rules govern PCB manufacture,
processing, and disposal, not solvent cleaning. U-Haul EHS practice: any U-Haul maintenance shop using solvent
degreasers must comply with NESHAP Subpart T recordkeeping, including solvent consumption logs and emission
calculations.
Q8. A U-Haul self-storage facility is located near a navigable waterway. An aboveground storage tank (AST)
at the site holds 8,000 gallons of motor oil for truck maintenance. Under the Clean Water Act's Spill
Prevention, Control, and Countermeasure (SPCC) rule (40 CFR 112), which statement is most accurate?
A. SPCC plans are required only for facilities with total aboveground oil storage capacity greater than 1,320
gallons where a discharge could reach navigable waters [CORRECT]
B. SPCC plans are required only for facilities with underground storage tanks; aboveground tanks are exempt
C. Any facility storing any quantity of oil must prepare an SPCC plan regardless of potential to reach navigable
waters
D. SPCC plans apply only to facilities drilling for oil, not to end-user sites such as U-Haul maintenance shops
Correct Answer: A
Rationale:
40 CFR 112 requires an SPCC plan for facilities with: (1) aggregate aboveground oil storage capacity greater than 1,320
gallons in containers of 55 gallons or more, OR (2) completely buried storage capacity greater than 42,000 gallons;
Page 4 | 100% Verified EHS Certification Content | 100 Total Questions
