Believe it or not, there are times when a shipping paper is not required for the transportation of a hazardous material in commerce.  Since it is the responsibility of the Shipper to describe the hazardous material on the shipping paper, your awareness of this exclusion is important.  The regulations for the applicability of the shipping paper to the transportation of a hazardous material are found at 49 CFR 172.200 and explained below. 

First of all, you may not use this exclusion if the material to be shipped is a hazardous waste, a hazardous substance, or a marine pollutant.  With that out of the way, the following materials do not require the use of a shipping paper:

• Those identified by the letter ‘A’ in column 1 of the Hazardous Materials Table found at 49 CFR 172.101, unless the material is transported by air (eg. Calcium Oxide).
• Those identified by the letter ‘W’ in column 1 of the Hazardous Materials Table, unless the material is transported by vessel over water (eg. Fish Meal, Stabilized or Fish Scrap, Stabilized).
• A limited quantity packaging unless transported by air or water.
• A package of ORM-D material when transported by highway or rail.  Note that the ORM-D classification will not be effective after December 31, 2020.
• A category B infectious substance prepared in accordance with 49 CFR 173.199.

Given the limited scope of the above, there’s a good chance that most shipments of a hazardous materials will require the use of a shipping paper.  That’s to be expected since the purpose of a shipping paper is to provide everyone involved in the shipment of hazardous materials the information they need to protect themselves and perform their jobs safely.  The shipping paper is the primary tool of the four hazard communication methods (shipping papers, placards, labels, and markings) to provide this information.

The shipment of hazardous materials can be tricky.  You are required to know the regulations and to properly prepare your hazardous materials for transportation in commerce.  Part of this is training your HazMat Employees to perform their jobs in compliance with the regulations.  Please contact me to discuss your training needs.