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. This 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. Yesterday we reviewed PHMSA guidance concerning multipage shipping papers and the sequence of the hazardous material description.
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Today we will take a look at PHMSA guidance concerning outdated shipping papers and accessibility of the shipping paper in the vehicle.
Can You Use Up Those Old Shipping Papers?
In a June 2016 rule, PHMSA revised certain Hazardous Materials Table (HMT) entries, including removing the packing group (PG) II designation for certain explosives. The intent was to alleviate confusion and align with international standards. Someone asked if they could continue to use preprinted shipping papers that list the PG II designation in the basic description.
The answer is “up to a point.” According to PHMSA, when a change is made to the HMT, shippers may continue to use preprinted shipping papers until the supply runs out or for 1 year after the effective date of the amendment. The effective date of this final rule was July 5, 2016, so the preprinted shipping papers may be used until they run out or through July 5, 2017, whichever comes first.
Mounting Shipping Papers on a Vehicle
Drivers and other such as inspectors and first responders must have easy accessibility to the shipping papers that apply to the hazardous materials being carried in a vehicle. Specific requirements concerning the storage of shipping papers on a vehicle are that:
- When the driver is at the vehicle’s controls, the shipping paper must be within his or her immediate reach while restrained by the seat belt and either readily visible to a person entering the driver’s compartment or in a holder that is mounted to the inside of the door on the driver’s side of the vehicle.
- When the driver is not at the vehicle’s controls, the shipping paper must be in a holder that is mounted to the inside of the door on the driver’s side of the vehicle or on the driver’s seat in the vehicle.
PHMSA provided guidance in a scenario where the shipping paper in a clear plastic sleeve was placed in a compartment or holder that is mounted on the inside of the driver’s side door. PHMSA determined that in this situation as long as the shipping paper is in immediate reach of the driver when at the vehicle’s controls and restrained by the seat belt, the storage meets the requirements. In addition, as long as the shipping paper remains in the manufactured compartment on the inside of the driver’s door when the driver is not at the vehicle’s controls, it also meets the shipping paper storage requirements.
You also do not have to permanently affix the shipping paper holder to the driver’s side of the vehicle for it to be considered “mounted.” PHMSA OK’d a scenario where a plastic sleeve was mounted by Velcro to the driver’s side door.