In an earlier article I used the regulations of the US DOT to debunk a common misconception that  the description of a hazardous material on a shipping paper or a marking on a package must appear exactly as it does in the Hazardous Materials Table; down to each and every comma.  In my days of driving a truck for Laidlaw Environmental Services I was told that each missing comma between the elements of a Basic Description:  Identification Number, Proper Shipping Name, Hazard Class, & Packing Group could result in a separate violation and fine.  This is not true.  The concern of the US DOT regarding the proper shipping description of a hazardous material is not its punctuation, but whether or not it communicates the hazards of the material in transportation.

There are, however, some situations where a specific form of punctuation is required by the Hazardous Materials Regulations (HMR):

1. 49 CFR 172.203(k) requires the Technical Name of the material be entered in (parenthesis) in association with the Basic Description (meaning, somewhere at the beginning or the end) if its entry in the Hazardous Materials Table includes the letter G in column 1.
2. §172.202(a)(3) requires the subsidiary hazard class(es) be entered in (parenthesis) immediately following the primary hazard class.  The presence of a subsidiary hazard class – or classes – will be indicated in column 6 of the Hazardous Materials Table.
3. If the hazardous material is a Hazardous Substance and the name of the Hazardous Substance is not a part of the Proper Shipping Name, then §172.203(c) requires the name of the Hazardous Substance, or a Hazardous Waste Code if applicable, be entered in (parenthesis) in association with the Basic Description.
4. If the hazardous material is a Marine Pollutant and the name of the Marine Pollutant does not appear in the Proper Shipping Name, then §172.203(l) requires the name of the Marine Pollutant be entered in (parenthesis) in association with the Basic Description.

There may be other regulations within the HMR that require the use of punctuation as part of the Basic Description, but these are the ones I am most familiar with, and the ones you are most likely to encounter.  If you have a question about the HMR (Hazardous Materials Regulations) of the US DOT or the hazardous waste regulations of the US EPA, please don’t hesitate to contact me.