A Shipper of a hazardous material is responsible for its classification and packaging prior to offering it for shipment to a Carrier.  An important, but often overlooked, requirement for the safe and regulatory compliant transportation of a HazMat is an understanding of the special provisions in column 7 of the Hazardous Materials Table.  When column 7 of the Hazardous Materials Table (49 CFR 172.101) includes a special provision code for an entry in the table, the requirement of that code – or codes, there may be several of them – is in addition to the general packaging requirements of §173.24 and any other applicable packaging requirements in Part 173.  Further, the limitations and/or additional requirements found in the special provisions of column 7 will supersede the packaging authorizations of column 8 of the Hazardous Materials Table.

The purpose of this article is to explain the meaning of the coding system for the Special Provisions of column 7 in order to facilitate your review and understanding of them and how they may apply to your shipment of a hazardous material.

For the regulatory description of the codes for special provisions, please refer to 49 CFR 172.102.

• A code consisting only of numbers (for example, “11”) is multi-modal in application and may apply to bulk and non-bulk packagings.  This is the code that every Shipper – and Carriers too! – must pay attention to as it applies to all packagings and all modes of transportation (aircraft, motor vehicle, rail, & vessel).
• A code containing the letter “A” refers to a special provision which applies only to transportation by aircraft.  If your shipment of HazMat is not by air, then this special provision will not be applicable.
• A code containing the letter “B” refers to a special provision that applies only to bulk packaging requirements. Unless otherwise indicated in the Hazardous Material Regulations, these special provisions do not apply to UN, IM Specification portable tanks or IBCs.  More about Bulk and Non-Bulk Packagings.  Special provisions specific to IBCs, and UN or IM Specification portable tanks exist as well and are identified below.
• A code containing the letters “IB” or “IP” refers to a special provision that applies only to transportation in IBCs and Large Packagings.  IBCs or Intermediate Bulk Containers are a specific type of bulk packaging that occupy a unique positions within the Hazardous Material Regulations.  A Large Packaging is a type of bulk packaging that is frequently used in multi-modal transportation (eg. vessel-to-highway-to-rail-to-highway).  Both are defined at 49 CFR 171.8.
• A code containing the letter “N” refers to a special provision which applies only to non-bulk packaging requirements.  More about Bulk and Non-Bulk Packagings.
• A code containing the letter “R” refers to a special provision which applies only to transportation by rail.  There is only one special provision code that contains the letter “R”:  R1; which refers to a shipment of sulfur, molten or residue of sulfur, molten.
• A code containing the letter “T” refers to a special provision which applies only to transportation in UN or IM Specification portable tanks.  “T” codes T1 through T22 specify the applicable minimum test pressure, the minimum shell thickness (in reference steel), bottom opening requirements and pressure relief requirements.
• A code containing the letters “TP” refers to a portable tank special provision for UN or IM Specification portable tanks that is in addition to those provided by the portable tank instructions or the requirements in part 178 of this subchapter.
• A code containing the letter “W” refers to a special provision that applies only to transportation by water.  There are only six “W” special provision codes that apply to the transportation of a hazardous material by vessel:  W1, W7, W89, W9, W10, & W41.

There you have it!  Use the above summary to assist you in reviewing the special provisions applicable to the HazMat you offer for transportation.