A question from an attendee of one of my recent training events forced me to re-think my strongly-held belief in the correct formatting of the proper shipping description for a hazardous materials shipment. The question asked was, “Is a comma required between the primary hazard class (3 in the example below) and the subsidiary hazard class (8 in the example)? Or, what if there is more than one subsidiary hazard class, must there be a comma between them?”
As a truck driver for Laidlaw Environmental Services for several years and ~13 years with Fehr-Graham and Associates (click here for more information), I have seen my share of shipping papers and thought I knew the correct answer. I believed that a comma must appear between every distinct entry in the proper shipping description.
For example: UN2924, Flammable Liquid, Corrosive, n.o.s., 3, (8), PGII, (Isopropanol, Organic Amines).
Research brought me to 49 CFR 172, Subpart C which documents the requirements for completing a shipping paper if required for a shipment of hazardous materials (all hazardous waste shipments from Large Quantity Generators and Small Quantity Generators of hazardous waste are required to use a Uniform Hazardous Waste Manifest which is a type of shipping paper). It does not however indicate specifically when – or if – commas are to be used. 49 CFR 172.202(a)(7)(b) of Subpart C reads, “Except as provided in this subpart, the basic description specified in paragraphs (a)(1), (2), (3) and (4) of this section must be shown in sequence with no additional information interspersed. For example, ‘UN2744, Cyclobutyl chloroformate, 6.1, (8, 3), PG II’.” This would seem to indicate that the preferred method, as indicated by the example, is to use commas to separate each distinct part of the basic description. However…
In the PHMSA webpage of FAQ’s, in a question regarding the order of information in the basic description the comma is not present between the primary hazard class and the subsidiary hazard classes. This would seem to indicate that the use of commas is arbitrary. And….
The Pipeline and Hazardous Materials Safety Administration (PHMSA) Hotline reported that they have no set formatfor separating the information contained in the basic description or what may be included as “additional description”.
Also, PHMSA written interpretation #05-0180 – while directly addressing another aspect of the basic description – includes the following statement, “The basic shipping description must be easily recognizable and available to emergency responders in the event of an incident.”
This brings us all the way back to the basic function of all four of the DOT hazard communication methods (shipping papers, placards, hazard labels, & markings): it’s all about communication; and not mindless adherence to the Hazardous Materials Regulations. The purpose of the proper shipping description on the shipping paper is to communicate the potential hazards of the hazardous material in transportation for all who may come in to contact with it, but especially for emergency responders. Therefore, as long as the proper sequence of the proper shipping description is maintained as per 49 CFR 172.202(a)(7)(b) – see example above – and the necessary information is communicated, a shipper may use commas, multiple spaces, hyphens, semi-colons, etc. in the proper shipping description as they see fit. So, the above example may appear correctly as it is, or as any of the following:
UN2924 Flammable Liquid, Corrosive, n.o.s. 3 (8) PGII (Isopropanol, Organic Amines)
UN2924 – Flammable Liquid, Corrosive, n.o.s. – 3 – (8) – PGII – (Isopropanol, Organic Amines)
UN2924; Flammable Liquid, Corrosive, n.o.s.; 3 (8); PGII (Isopropanol, Organic Amines)
In addition, per 49 CFR 172.101(c)(2) punctuation marks and words in italics are not part of the proper shipping name, but may be used. So, commas are not even required within the proper shipping name, meaning any of the following proper shipping descriptions are acceptable as well:
UN2924 Flammable Liquid Corrosive n.o.s. 3 (8) PGII (Isopropanol, Organic Amines)
UN2924 – Flammable Liquid Corrosive n.o.s. – 3 – (8) – PGII – (Isopropanol, Organic Amines)
UN2924; Flammable Liquid Corrosive n.o.s.; 3 (8); PGII (Isopropanol, Organic Amines)
Researching this question served as a good reminder for me that no part of the HMR – even a comma – is so small it’s unimportant.