Q&A: What is the proper shipping description for a limited quantity of HazMat by vessel?

Q&A: What is the proper shipping description for a limited quantity of HazMat by vessel?

Q&A: What is the proper shipping description for a limited quantity of HazMat by vessel?

Question (May 02, 2018):

I have had no official training, but I have been brokering Hazardous shipment(s) for approx 25 years.
I wanted to make sure that the BOL I prepared is correct.

UN 3208 Metallic Substance, Water-Reactive NOS (Magnesium, Class 4.3, PG II, Limited Quantity, F-G, S-N

Emergency Phone ###-###-####

My reply that same day:

Please see below.

Overall, the shipping description appears correct.  Please see below for further guidance.

Note: Since you represent a trucking company within the U.S., I presume at least part of the transport to be by U.S. highway.  Also, though not indicated in your question, I presume this consignment is to be transported by vessel according to the International Maritime Organization Dangerous Goods Code (IMDG Code).  I’ll indicate how I came to this second conclusion while answering your question.Model container ship

  • The sequence to the basic description is correct.
    • UN/ID number: UN3208
    • Proper shipping name: METALLIC SUBSTANCE, WATER-REACTIVE, N.O.S.  The proper shipping name is displayed in uppercase letters in the IMDG Code. It is acceptable to be displayed in lowercase letters.
    • Hazard class: Class 4.3. Class 4.3 is Dangerous When Wet.  Note: Class 4.3 is how it is identified in the IMDG Code.  The USDOT/PHMSA Hazardous Materials Regulations refers to it as Division 4.3. 
    • Packing Group: PG II.  PG II is the medium / moderate level of danger for a hazardous material / dangerous good.
  • An additional description of the hazardous material / dangerous good is required as well:
    • Since this is a generic proper shipping name, at least one technical name of a constituent of the hazardous material / dangerous good must be included with the shipping description.  The technical name must be contained within parenthesis (brackets).  You indicate “Magnesium” but do not have it contained within parenthesis.
    • “Limited Quantity” or “Ltd Qty” is to be included as an additional description if the hazardous material / dangerous good is to offered for transport by vessel or air subject to the limited quantity exception.  Both the IMDG Code and the USDOT/PHMSA Hazardous Materials Regulations have similar requirements for packaging and hazard communication of a limited quantity.  Note: A shipping paper is not required for the transport of a limited quantity by highway or rail within the U.S., but is required for transport by vessel.  I therefore again presume that this consignment is to be transported by vessel per the IMDG Code.
    • Subject to the IMDG Code, it may be a limited quantity only if the net quantity of dangerous good in a single packaging is no more than 500 grams and if the gross package weight does not exceed 30 kg.

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  • “F-G, S-N” are the relevant emergency schedules for FIRE and SPILLAGE in the EmS Guide for this dangerous good.  It is identified in column 15 of the IMDG Code’s Dangerous Goods List.  This information – along with the emergency phone indicated – can fulfill part of your responsibility as the shipper to provide emergency response information to the carrier.  Note: the EmS Guide is not identified in the USDOT/PHMSA Hazardous Materials Regulations (another indication of this consignment’s transport) but may be acceptable as a source of emergency response information it requires.
  • You do not indicate a total quantity of hazardous materials / dangerous goods nor a number and type of packaging.  I presume you are satisfied with these aspects of the shipping description.

Please contact me with any other questions or comments.

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

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion / Summary:

I did not receive confirmation from my questioner but I believe my presumptions to be correct.  A question then: Is it OK to prepare and offer for transport a consignment of a hazardous material / dangerous good in compliance with the IMDG Code when some of the transport is by highway within the U.S.? Answer: yes!  The Hazardous Materials Regulations of USDOT/PHMSA at 49 CFR 171.23 and §171.25 allow for the transport of a hazardous material (the IMDG Code refers to it as a dangerous good) according to the international regulations of the IMDG Code within the U.S. as long as the shipper complies with the additional requirements and limitations identified in those sections.

And wow! “I have had no official training…” just knocks me out.  The regulations of both USDOT/PHMSA and the IMDG Code require any person with a direct affect on the safe transport of hazardous materials / dangerous goods to receive initial training (within 90 days) with a triennial renewal (every three years).