Daniels Training Services

Using a “Permanent” Shipping Paper for the Transportation of Hazardous Materials

Using a “Permanent” Shipping Paper for the Transportation of Hazardous Materials

In an earlier article I explained some of the different forms a Shipping Paper may take, such as a Bill of Lading, Uniform Hazardous Waste Manifest, and others.  In a subsequent article I identified the information that must be included as the hazardous materials description on a shipping paper.  There are some situations where the use of a shipping paper for each shipment of a hazardous material is burdensome and, as it turns out, unnecessary.  For example, a company may use its own trucks and drivers to deliver Liquified Petroleum Gas (LPG) to several locations.  The driver starts with a large volume of HazMat which declines in volume as deliveries are made at each client site.  The hazardous material (LPG) remains the same, the only thing that changes is the reduction in volume.

In the above example, may a carrier use a single shipping paper, without change, for multiple shipments of one or more hazardous materials (assuming each separate hazardous material has the same shipping name and identification number) instead of using a separate shipping paper for each delivery?  The answer is yes.  Such a document is known as a “Permanent” Shipping Paper and is allowed pursuant to 49 CFR 172.201(e):

A motor carrier (as defined in §390.5 of subchapter B of chapter III of subtitle B) using a shipping paper without change for multiple shipments of one or more hazardous materials having the same shipping name and identification number may retain a single copy of the shipping paper, instead of a copy for each shipment made, if the carrier also retains a record of each shipment made, to include shipping name, identification number, quantity transported, and date of shipment.

This interpretation letter from the PHMSA explains further its acceptance of the use of a “Permanent” Shipping Paper based on §172.201(e) (03-0003).

If using a “Permanent” Shipping Paper, the carrier must retain a record of each shipment made.  This could be a delivery or billing receipt or some other company-specific document.  Pursuant to 49 CFR 172.201(e) the record for each shipment must include the following:

  1. Shipping name.
  2. Identification number.
  3. Quantity transported.
  4. Date of shipment.

As LOI 03-0003 goes on to explain, the delivery of a partial amount of the hazardous material does not require a change to the “Permanent” Shipping Paper but the pick up of additional quantities of hazardous materials that are not described on the shipping paper does require a modification to the “Permanent” Shipping Paper if the total quantity on the vehicle ever exceeds the amount described on the shipping paper.

The use of a “Permanent” Shipping Paper could be a great benefit to a carrier who makes a large number of deliveries of the same hazardous material(s).  One of the things I enjoy most about training is bringing something like this to the attention of someone in the industry who needs to know.  Contact me about my training services and see what you can learn that will benefit you.