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How to Distinguish a Hazardous Material From non-Hazardous Material on a Shipping Paper

How to Distinguish a Hazardous Material From non-Hazardous Material on a Shipping Paper

When preparing a shipping paper you are required to distinguish the hazardous materials (such as solvent-based paints, resins, adhesives, acids, etc.) from any materials that are not hazardous (hydraulic oils, water-based paints, pallets, widgets, etc.).  49 CFR 172.201(a)(1) specifies your options to distinguish the hazardous materials from the non-hazardous, they are:

  1. Enter the hazardous material first in order of appearance.
  2. Print the basic description of the hazardous material (Identification Number, Proper Shipping Name, Hazard Class, & Packing Group) in a color that clearly contrasts with the shipping description of the non-hazardous material.
  3. If the shipping paper is a reproduction, where a difference in ink color won’t be detected, the entry for a hazardous material may be highlighted with a contrasting color to distinguish if from non-hazardous materials.
  4. If a column captioned ‘HM’ (for Hazardous Material) before the basic description is present, you may place an ‘X’ in this column on the same line as the entry for the hazardous material.  Entries for non-hazardous materials would not receive an ‘X’ in the ‘HM’ column.  You may replace the ‘X’ with ‘RQ’ if the hazardous material is also a Reportable Quantity of a hazardous substance.

Whether you prepare shipping papers, which includes Bills of Lading and Uniform Hazardous Waste Manifests, or merely review and sign them, you must be aware of these requirements to distinguish the hazardous materials from non-hazardous materials.

Contact me for a free consultation on your HazMat Employee and RCRA Personnel training needs.