49 CFR 172.600 mandates the shipper of a hazardous material to provide emergency response information specific to each hazardous material that appears on the shipping paper. Emergency response information is not required in only two situations:
- If the shipment does not require a shipping paper, and;
- If the shipment is a properly classified ORM-D material.
A common method of compliance with this regulation is for the shipper to provide the carrier with the applicable page from the Emergency Response Guidebook (copied or printed) and document the Guide Number page near the description of the HazMat on the shipping paper. However, this practice alone, without additional information provided by the shipper, is a violation of the Hazardous Material Regulations (HMR) of the PHMSA/USDOT.
49 CFR 172.602(a)(1) states that the emergency response information for a HazMat shipment must contain the following:
- The hazardous material’s basic description, and;
- The hazardous material’s technical name, if required.
49 CFR 172.602(a)(2) lists other required emergency response information, read about it here. But it is in §172.602(a)(1) where the critical requirement can be found; note that it requires the emergency response information to include both the basic description and the technical name.
The basic description (read more about it here) of a hazardous material contains the following four elements:
- Identification number
- Proper shipping name
- Hazard class
- Packing group
The technical name is the chemical name of a hazardous material or one or more of the constituents of a mixture that make it hazardous. Read more about the use of the technical name of a HazMat with its proper shipping name.
Refer to the orange pages of the Emergency Response Guidebook where the emergency response information is found and you will notice that the pages do not contain the basic description nor the technical name of the hazardous material. Therefore, if you intend to provide the Guide Number page from the Emergency Response Guidebook, then you will have to add the basic description and the technical name (if required) to the page.
There is another way to fulfill the requirement to provide emergency response information: ensure the entire Emergency Response Guidebook is present on the transport vehicle. In this case it is not required for you to indicate the Guide Number of the hazardous material on the shipping paper in association with the description of the HazMat; though you are not prohibited from doing so.
Refer to this USDOT/PHMSA letter of interpretation for confirmation of this information (12-0068).
Please contact me to schedule HazMat Employee Training for your personnel. You may also wish to consider my services for Hazardous Waste Personnel training required per the USEPA’s RCRA regulations.