Pursuant to 49 CFR 172, Subpart C, the shipper of a hazardous material (HazMat) is required to prepare a shipping paper that – unless specifically excepted by the Hazardous Material Regulations – includes the following information:
The HazMat’s basic description [§172.202(a)(1-4)].
Total quantity of HazMat (unless by air) [§172.202(a)(5)]. Total quantity by air is at §172.202(a)(6).
Number and type of packages [§172.202(a)(7)].
The HazMat’s additional description, if necessary (§172.203)
Emergency response telephone number [§172.201(d)].
Shipper’s certification (§172.204).
And pursuant to §172, Subpart G, emergency response information must be immediately available for use whenever a HazMat is present in transportation.
But we’re not here to review the requirements for a HazMat Shipping paper, the purpose of this article is to identify and explain the requirements of the Dangerous Cargo Manifest when a hazardous material is transported by vessel. (more…)
Chapter 5.4 of the International Maritime Dangerous Goods Code (2012 Edition) indicates the requirements of the International Maritime Organization (IMO) for the description of a dangerous good on a shipping paper (referred to in the IMDG Code as a dangerous goods transport document) to be offered for transportation by vessel in international waters. The purpose of this article is to summarize the general requirements for a Shipper preparing a dangerous goods transport document. (more…)
The regulations of the the Resource Conservation and Recovery Act (RCRA) apply generally to any hazardous waste generated, transported, treated, stored, or disposed of within the US. But what of a hazardous waste generated in waters off the coast of the US, perhaps on a vessel or an oil platform or rig? The purpose of this article is to explain the applicability of the hazardous waste regulations of the USEPA and the HazMat Transportation regulations of the USDOT/PHMSA to the generation and transportation of hazardous waste within and without US territorial waters. (more…)
A Bulk Packaging, defined at 49 CFR 171.8: “Means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has:
A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or
A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.”
Simple enough, but why is it that a vessel or barge is specifically excluded from the definition of a Bulk Packaging?
Before we get to the answer, let’s make sure we understand the terms, both of which are defined at 49 CFR 171.8:
“Vessel includes every description of watercraft, used or capable of being used as a means of transportation on the water.”
“Barge means a non-self propelled vessel.”
The answer, is that any material, including a hazardous material, loaded directly into the hold of a vessel or barge is subject to the regulations of the US Coast Guard and not the Pipeline and Hazardous Materials Administration (PHMSA) of the US DOT and therefore not subject to the Hazardous Material Regulations.
The transportation of hazardous materials involves many different methods (air, water, highway, rail) each of which is subject to the regulations of the PHMSA. But other Federal agencies have their own authority and their own regulations that may impact the shipment as well. Learn what you need to know about the transportation of hazardous materials at my training, either On-Site or Public Workshop/Open Enrollment. Contact me for a free consultation on your training needs.
purpose of this article is to identify and explain the requirements of the Dangerous Cargo Manifest when a hazardous material is transported by vessel. (more…)