Proper Shipping Description

Punctuation in the Proper Shipping Name and Basic Description for a Hazardous Material

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.

Use of the Technical Name with the Proper Shipping Name When Shipping HazMat

When determining a proper shipping name for your hazardous materials shipment it is important to select from the Hazardous Materials Table at 49 CFR 172.101 the most specific name that best describes the hazardous material to be shipped.  Proper shipping names should be selected in the following order:

  1. The chemical identity of the hazardous material:  its technical name.
  2. The name of a category or group of chemicals, e.g. “Alcohols, n.o.s.”
  3. The intended use of the material, e.g. “Resin Solution”.
  4. It describes the hazard(s) of the material, e.g. “Flammable Liquid, n.o.s.”

It is when the fourth option of the above is chosen that you must pay special attention to column 1 of the Hazardous Materials Table and see if the letter ‘G’ appears there.  The ‘G’ stands for Generic and means that the proper shipping name selected does not go far enough to describe the hazards of the material it represents.  It is necessary therefore to include the technical name of the hazardous material on the shipping paper.  Technical Name is defined at 49 CFR 171.8 and means a recognized chemical name used by science.  It does not allow for the use of trade names.

The regulations at 49 CFR 172.203(k) indicate the correct use of the technical name on the shipping paper; please continue for a summary of this information.

If the material is not a mixture or solution, than you need use only one technical name.  It must appear in parenthesis and be associated with the basic description.  It may appear thus:

“Corrosive liquid, n.o.s., (Octanoyl chloride), 8, UN 1760, II”, or

“Corrosive liquid, n.o.s., 8, UN 1760, II (contains Octanoyl chloride)”

Note that the use of the word “contains” is allowed, but not required.

If the hazardous material is a mixture or solution of two or more hazardous materials, then the technical names ofat least two hazardous components that contribute the most to the hazards of the material must be listed on the shipping paper as indicated above.  Note that you are required to list “at least two” of the most dangerous constituents, but no upper limit is set.  You may therefore list as many hazardous ingredients as you wish as long as the first two listed are the major contributors to the hazards of the material.  Also note that you are only required to list the hazardous constituents.  If you have a mixture of a hazardous material and non-HazMat, you are not required to list the non-HazMat.

Many people equate the presence of the “n.o.s.” (“not otherwise specified”) at the end of the proper shipping name to be synonymous in meaning with a ‘G’ in column 1, but this is not so.  There are several proper shipping names with “n.o.s.” – such as “Alcohols, n.o.s.” that lack a ‘G’ in column 1.  The regulations at 49 CFR 172.203(k) are clear that the technical name is required on a shipping paper only when a ‘G’ is found in column 1.

For organic peroxides which may qualify for more than one generic listing depending on concentration, the technical name must include the actual concentration being shipped or the concentration range for the appropriate generic listing.

Shipping descriptions for toxic materials that meet the criteria of Division 6.1, PG I or II (Poisonous Material) or Division 2.3 (Poisonous Gas) and are identified by the letter “G” in column 1 of the §172.101 Table, must have the technical name of the toxic constituent entered in parentheses in association with the basic description.

There are some situations where the use of a technical name is not required even if a “G” appears in column 1 of the Hazardous Materials Table.  If a material is a hazardous waste and is described using the proper shipping name of Hazardous waste, solid, n.o.s. or Hazardous waste, liquid, n.o.s. (class 9) it need not include the technical name provided the US EPA hazardous waste code is included near the basic description the same as the requirement for the technical name.  Or, if the material is a reportable quantity of a hazardous substance, you may describe it as required in 49 CFR 172.203(c) instead.

A technical name is also not required if you are shipping a sample of a material for analysis and the hazard class is not known.  Read my article about the US EPA and US DOT requirements for managing samples of hazardous materials.

49 CFR 172.203(k)(2)(iii-iv) allow for a relaxation of the requirement for a technical name in certain rare situations where the proper shipping name – though containing “n.o.s.” – is descriptive enough of the hazards of the material.  I suggest you read these two specific regulations to see if they apply to your operations.

Another exception for the use of the technical name can be found at 49 CFR 173.12 and applies solely to shipments of hazardous waste in lab packs.  I don’t have time to explain lab packs here, but suffice to say that as long as your lab pack shipment of hazardous waste meets the requirements of 49 CFR 173.12(b), then pursuant to 49 CFR 173.12(d) you need not include the technical name on the shipping paper or as a marking on the package.

All of the above is required to appear on the shipping papers, what about on the packaging as a marking?  49 CFR 172.301(b) specifies the requirements for including the technical name on a non-bulk packaging (<119 gallons) as the same as those required on a shipping paper.  Therefore the appearance of the technical name on the shipping paper should match its appearance on the packaging as a marking for non-bulk packages.

49 CFR 172.302 – General Marking Requirements for Bulk Packagings does not include a requirement for the proper shipping name on a bulk packaging unless it is a portable tank or a railroad tank car.  Therefore, the technical name is not required for bulk packagings except in the case of a portable tank or a railroad tank car.

Questions like these come up frequently at the HazMat Courses I hold nationwide and year-round.  My training events meet the regulatory requirements of the US EPA for RCRA training and those of the US DOT for HazMat Employees.  Both together in one day of training.  Please refer to my Schedule of Events to find a training event date and location convenient to you.  Or, contact me directly to schedule on-site training for all of your Hazardous Waste Personnel and HazMat Employees in one day of training for only $1,749.

Use of Commas in the Proper Shipping Description for Hazardous Materials

A question from an attendee of one of my recent training events forced me to re-think my strongly-held belief in the correct formatting of the proper shipping description for a hazardous materials shipment.  The question asked was, “Is a comma required between the primary hazard class (3 in the example below) and the subsidiary hazard class (8 in the example)?  Or, what if there is more than one subsidiary hazard class, must there be a comma between them?”

As a truck driver for Laidlaw Environmental Services for several years and ~13 years with Fehr-Graham and Associates (click here for more information), I have seen my share of shipping papers and thought I knew the correct answer.  I believed that a comma must appear between every distinct entry in the proper shipping description.

For example: UN2924, Flammable Liquid, Corrosive, n.o.s., 3, (8), PGII, (Isopropanol, Organic Amines).

Research brought me to 49 CFR 172, Subpart C which documents the requirements for completing a shipping paper if required for a shipment of hazardous materials (all hazardous waste shipments from Large Quantity Generators and Small Quantity Generators of hazardous waste are required to use a Uniform Hazardous Waste Manifest which is a type of shipping paper).  It does not however indicate specifically when – or if – commas are to be used.  49 CFR 172.202(a)(7)(b) of Subpart C reads, “Except as provided in this subpart, the basic description specified in paragraphs (a)(1), (2), (3) and (4) of this section must be shown in sequence with no additional information interspersed. For example, ‘UN2744, Cyclobutyl chloroformate, 6.1, (8, 3), PG II’.”   This would seem to indicate that the preferred method, as indicated by the example, is to use commas to separate each distinct part of the basic description.  However…

In the PHMSA webpage of FAQ’s,  in a question regarding the order of information in the basic description the comma is not present between the primary hazard class and the subsidiary hazard classes.  This would seem to indicate that the use of commas is arbitrary.  And….

The Pipeline and Hazardous Materials Safety Administration (PHMSA) Hotline reported that they have no set formatfor separating the information contained in the basic description or what may be included as “additional description”.

Also, PHMSA written interpretation #05-0180 – while directly addressing another aspect of the basic description – includes the following statement, “The basic shipping description must be easily recognizable and available to emergency responders in the event of an incident.”

This brings us all the way back to the basic function of all four of the DOT hazard communication methods (shipping papers, placards, hazard labels, & markings):  it’s all about communication; and not mindless adherence to the Hazardous Materials Regulations.   The purpose of the proper shipping description on the shipping paper is to communicate the potential hazards of the hazardous material in transportation for all who may come in to contact with it, but especially for emergency responders.  Therefore, as long as the proper sequence of the proper shipping  description is maintained as per 49 CFR 172.202(a)(7)(b) – see example above – and the necessary information is communicated, a shipper may use commas, multiple spaces, hyphens, semi-colons, etc. in the proper shipping description as they see fit. So, the above example may appear correctly as it is, or as any of the following:

UN2924   Flammable Liquid, Corrosive, n.o.s.   3   (8)   PGII   (Isopropanol, Organic Amines)

UN2924 – Flammable Liquid, Corrosive, n.o.s. – 3 – (8) – PGII – (Isopropanol, Organic Amines)

UN2924; Flammable Liquid, Corrosive, n.o.s.; 3  (8); PGII  (Isopropanol, Organic Amines)

In addition, per 49 CFR 172.101(c)(2) punctuation marks and words in italics are not part of the proper shipping name, but may be used.  So, commas are not even required within the proper shipping name, meaning any of the following proper shipping descriptions are acceptable as well:

UN2924   Flammable Liquid Corrosive n.o.s.   3   (8)   PGII   (Isopropanol, Organic Amines)

UN2924 – Flammable Liquid Corrosive n.o.s. – 3 – (8) – PGII – (Isopropanol, Organic Amines)

UN2924; Flammable Liquid Corrosive n.o.s.; 3  (8); PGII  (Isopropanol, Organic Amines)

Researching this question served as a good reminder for me that no part of the HMR – even a comma – is so small it’s unimportant.