A question from within the regulated community, August 8, 2017. Sent from a contact form on my website:
I have a rather easy question but I would like some clarification. Our company transports HM for a customer and I noticed something that looks a little off on their pre-printed HM BOL’s. They list no Unit of Measure (e.g., 1 Tanker) however they list a volume in gallons before the HM description, for example: # of gallons – UN1170, Ethyl Alcohol, 3, PGII.
Per CFR §172.202(a)(5) it appears their BOL is printed incorrectly as it does no have a UOM. Can this method be used and still remain in compliance with regulation?
My training tells me it should listed in this manner: 1 Tanker – UN1170 Ethyl Alcohol 3 PGII. # of gallons. Am I correct?
Regards,
My reply that same day:
Thank you for contacting me. I will try to answer your question. Please see below.
- Per 49 CFR 172.202(a)(5) the total quantity of HazMat on a shipping paper (e.g. bill of lading) must be indicated by mass or volume and must include an indication of the unit of measure.
- Per §172.202(a)(5)(iii) the following are excepted from the above requirement: Bulk packages, provided some indication of the total quantity is shown. e.g. “1 cargo tank” or “2 IBCs”. In other words, the total quantity and UOM of a HazMat is not required for a tanker (aka: cargo tank).
- Per §172.202(c)(1) the total quantity of the material must appear before or after, or both before and after the basic description. Abbreviations may be used for UOM.
- The total quantity in gallons is not required on a shipping paper for a bulk packaging such as a tanker truck. An indication of the total quantity e.g. “1 cargo tank” will suffice.
- If a total quantity is displayed then a unit of measure must be displayed as well. It is a violation to display the quantity in gallons and not have the unit of measure.
The safest thing to to is to remove the total quantity and unit of measure and go with just the indication of total quantity: “1 cargo tank” either before or after the basic description.
I hope this helps.
Please don’t hesitate to contact me with any other questions.
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But he still had some questions for me (08.08.17):
Relating your explanation below to my customers pre-printed HM BoL’s, it appears since they use a UOM in gallons on their pre-printed BoL’s they will need to hand write the total quantity (1 Tanker) after the basic description. Will this meet compliance if done this way?
And I had a reply (08.08.17):
Please see below:
- The total quantity in gallons is not required for a tanker. Simply “1 tanker” will suffice for both the total quantity and the number and type of packaging.
- If a total quantity in gallons is used it must also include the UOM.
- If the BoL already displays the total quantity in gallons and the UOM then all that is required is the number and type of packaging. In that case “1 tanker” will suffice. The number and type of packaging can be displayed before or after the basic description.
I hope that answers your question? If still unclear perhaps I will understand better if you email me a scanned copy of the BoL with the relevant information.
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Questioner did just what I requested and sent me a copy of the bill of lading:
I really appreciate your assistance. I have attached a copy of the information in question.
Having the BoL in question in front of me was very helpful. I now had a final answer ready:
I understand better now. Unless I am missing something, the BoL does indicate the total quantity with the UOM. The placement before the basic description is acceptable. It is, however, lacking the number and type of packages required by §172.202(a)(7). As you indicated earlier, this can be added after the basic description as “1 cargo tank”.
I hope THAT answers your question.
Daniel,
Thank you for your assistance, your guidance has helped.
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Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |