Here’s a question back on January 8, 2016 from a frequent customer of mine:
Hi Dan,
I have a hazardous material that doesn’t have a packing group in the hazardous materials table in §172.101, and I’m stuck. I need to ship this material (signals, distress, ship UN0506) soon and need some direction. Any help would be greatly appreciated!
Here’s me With my Snappy Reply a few moments later:
I’m on it.
Give me a minute and I’ll get you a reply.
Dan
And the Final Answer Maybe an Hour Later:
OK. Here we go:
- UN0506, Signals, distress, ship is a hazard class 1.4S Explosive.
- Most Class 1 Explosives do not have a packing group or default to packing group II.
- Packing instructions for this HazMat are found at 49 CFR 173.62 (see column 8B of the hazardous materials table).
- Explosives Table at 49 CFR 173.62 references packing instructions 135 for UN0506.
- Packing instructions 135 (also in 49 CFR 173.62) indicate the authorized packaging (inner, intermediate, & outer):
- Must follow general packing requirements of 49 CFR 173.60. These are pretty much common sense, e.g. “Inner packagings, fittings, and cushioning materials, and the placing of explosive substances or articles in packages, must be such that the explosive substance is prevented from becoming loose in the outer packaging during transportation.” and more.
Also…
- Packaging must meet packing group II requirements. This means the packaging must have an X (PG I, II, III) or Y (PG II, III) in the second set of alpha-numeric code that makes up the UN specification marking on the packaging.
- UN specification marking will also show the maximum gross weight for the packaging. This max gross weight includes the weight of the packaging and the HazMat.
I hope this helps. Please don’t hesitate to contact me with any questions.
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Turns out, the customer did have some more questions for me (January 8, 2016):
I actually looked in your blog for the answer, as well as past training materials after looking at the SDS. As of two days ago, I thought PG II, then the more I read into it, the more I doubted it. Would the following be acceptable for the label: 1 Fibreboard box, UN0506, signals, distress, 1.4S, PG II, and then the weight?
Thanks again!
My final answer:
Regarding HazMat labels & markings:
- Identification number (UN0506) and proper shipping name (Signals, distress. “ship” is optional).
- HazMat label for Division 1.4S Explosive.
- The other information you write of do not need to appear on the packaging as a label or marking, but they may need to appear on the shipping paper.
- Do not use PG II on the shipping paper or anywhere else as it does not apply.
- There may be a requirement for an additional description on the shipping paper if shipping by vessel.
- Transportation by vessel and motor vehicle may have segregation requirements.
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