As a Shipper you are required to classify a hazardous material prior to offering it for transportation; to do this you must be familiar with the definition of a hazardous material at 49 CFR 171.8.

Hazardous material means a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see 49 CFR 172.101), and materials that meet the defining criteria for hazard classes and divisions in part 173 of this subchapter.

Since the definition of a hazardous material includes “…materials that meet the defining criteria for hazard classes and divisions…” it is critical that you know what those hazard classes and divisions are.  49 CFR 173.2 indicates the hazardous material classes and divisions determined by PHMSA for the classification of a hazardous material; they are:

• Class 1 Explosives
  • Division 1.1 Explosives with a mass explosion hazard
  • Division 1.2 Explosives with a projection hazard
  • Division 1.3 Explosives with predominately a fire hazard
  • Division 1.4 Explosives with no significant blast hazard
  • Division 1.5 Very insensitive explosives; blasting agents
  • Division 1.6 Extremely insensitive detonating substances
• Class 2 Compresses gases
  • Division 2.1 Flammable gas
  • Division 2.2 Non-flammable compressed gas
  • Division 2.3 Poisonous gas
• Class 3 Flammable and combustible liquid
• Class 4 Flammable and reactive solids
  • Division 4.1 Flammable solid
  • Division 4.2 Spontaneously combustible material
  • Division 4.3 Dangerous when wet material
• Class 5 Oxidizers and organic peroxides
• Division 5.1 Oxidizer
• Division 5.2 Organic peroxide
• Class 6 Poisonous/Toxic materials
  • Division 6.1 Poisonous materials
  • Division 6.2 Infectious substances (Etiologic agent)
• Class 7 Radioactive material
• Class 8 Corrosive material
• Class 9 Miscellaneous hazardous material
• Other Regulated Material: ORM-D

But what if your hazardous material is not listed by its technical name in the Hazardous Materials Table of 49 CFR 172.101 and it meets the defining criteria of more than one hazard class or division?  What then?  In that case, the Shipper must determine which of the hazards is the primary and which is the subsidiary – or subsidiaries if there is more than one.  The purpose of this article is to explain the procedure at 49 CFR 173.2a for classifying a hazardous material that has more than one hazard. (more…)