Under the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulations, no one may ship a hazardous material or carry a hazardous material in transportation without a shipping paper. Seems pretty clear, but shipping paper violations continue to rank high on the Department of Transportation’s (DOT) list of hazmat violations uncovered during roadside inspections. To clear up some confusion regarding shipping paper requirements, we will take a look at some recent PHMSA guidance on the matter.
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The Case of the Orange Tab
One corporation recently asked PHMSA if using a multipage shipping paper consisting of a bill of lading and an attached shipping paper containing the hazardous material information satisfied the shipping paper requirements. They also use an orange tab to identify the shipping paper that contains the hazmat information.
According to PHMSA officials, this system appears to be up to snuff. A shipping paper may consist of more than one page if each page is consecutively numbered and the first page has a notation specifying the total number of pages. Hazardous material and nonhazardous material information may be listed on the same shipping paper (single or multipage) as long as the hazardous material information is either listed first, entered in a contrasting color, or identified by placing an “X” before the basic shipping description. Drivers and carriers must clearly distinguish a hazardous material shipping paper by either distinctly tabbing it or having it appear first.
Put the Info in the Right Sequence
PHMSA regulations require that the basic description of hazardous material be entered in the correct sequence on the shipping paper. Although certain information may be placed before the basic description, such as quantity shipped, the type of packaging, and distinction marks, additional information must be entered on the shipping paper after the basic description.
The required basic description includes:
- The identification number for the material as shown in Column (4) of the Hazardous Materials Table (49 CFR 172.101);
- The proper shipping name for the material in Column (2) of the table;
- The hazard class or division number for the material, as shown in Column (3) of the table;
- The packing group in Roman numerals, as designated for the hazardous material in Column (5) of the table.
The above four are the “basic description”: requirements that have to be in the right sequence. There are three other description requirements:
- Except for transportation by aircraft, the total quantity of hazardous materials covered by the description must be indicated. There are specific requirements for certain materials and packages.
- For transportation by aircraft, the total net mass per package, must be shown unless a gross mass is indicated in Columns (9A) or (9B) of the table in which case the total gross mass per package must be shown. There are specific requirements for certain materials and packages.
- The number and type of packages must be indicated either before or after the required basic description. The type of package must be a description of the packages that is a commonly recognizable package type. An example given is “12 drums.”
The number and type of package may not be split in two. PHMSA made this point in response to a query as to whether the number could be placed before the basic description and the type of package after. Part of the reasoning is that emergency responders must be able to easily ascertain the number of packages in a given shipment when determining emergency response actions.
Tune in to tomorrow’s Advisor for more shipping paper clarifications.