If you are a carrier or shipper of hazardous materials, you should already be familiar with the Hazardous Materials Table. Found at 49 CFR 172.101, it contains the necessary information to complete the shipping paper and comply with other aspects of the Hazardous Material Regulations (HMR) of the Department of Transportation. You may not be familiar with the purpose and importance of the symbols that may be found in Column 1 of the HMT. These symbols (+, A, D, G, I, W), if present, will affect how the hazardous materials shipment is prepared and transported.
- The plus (+) sign fixes the proper shipping name, hazard class and packing group – but not the identification number – whether or not the material actually has the hazards of that class, packing group or any other hazard class definition. It’s purpose is to indicate a material that is known by the DOT to pose a risk to humans, such as: Aniline, Benzaldehyde, Bromine, Sulfuryl Chloride, and others. There may be times where the plus sign is assigned to a mixture or solution where the hazard to humans differs from that of the pure material (think methanol mixed with soil and water). In that case you may select an alternative shipping name that represents the hazards posed by the material (LOI 04-0204).
- The letter ‘A’ means the HMR only applies to the material if it is to be transported by aircraft. However, the HMR does apply, regardless of the mode of transportation, if the material is a hazardous substance or hazardous waste (check US DOT definitions at 49 CFR 171.8). A shipping description with ‘A’ in column 1 of the HMT may be used for a material to be transported by vessel or motor vehicle provided all applicable requirements of the HMR are met.
- The letter ‘D’ identifies a proper shipping name that is accepted for domestic transportation, but may not be acceptable for transportation under international regulations (the International Maritime Organization or International Civil Aviation Organization). An alternate proper shipping name may be selected for either domestic or international transportation.
- The letter ‘G’ identifies proper shipping names for which one or more technical names of the hazardous material must be entered in parentheses, near the basic description. This past article of mine explains in detail the requirements of 49 CFR 172.203(k) and the use of the technical name.
- The letter ‘I’, a counterpart to letter ‘D’, identifies proper shipping names which are accepted for international transportation of HazMat. An alternate proper shipping name may be selected when only domestic transportation is involved.
- The letter ‘W’, a fellow traveler with letter A, denotes a material that is subject to the requirements of the HMR only when transported by vessel (which means any form of watercraft used as a means of transportation on the water). Just like the letter ‘A’, the requirements of the HMR do apply if the material is a hazardous substance or a hazardous waste. A shipping description with ‘W’ in column 1 of the HMT may be used for a material to be transported by aircraft or motor vehicle provided all applicable requirements of the HMR are met.
A full understanding of the Hazardous Material Regulations of the DOT must include the use of the Hazardous Materials Table to determine the proper shipping description for your hazardous materials. I provide training on the regulations of the DOT pertaining to the shipment of HazMat and those of the EPA for the generation of hazardous waste. Contact me for a free consultation of your training needs.