Unless an exception exists, the Hazardous Material Regulations (HMR) of the USDOT/PHMSA require the use of the four hazard communication methods when a hazardous material is offered for transportation; these are:
- Shipping Papers
- Placards
- HazMat Labels
- Markings
Markings are information affixed to the outside of the package, freight container, or transport vehicle used to communicate information about the hazardous material inside. This article will explore one of the requirements for marking a non-bulk HazMat packaging: the consignee’s or consignor’s name and address.
The requirements for marking a packaging are found at 40 CFR 172, Subpart D – Marking, the general marking requirements for a non-bulk packaging are at §172.301, the regulations pertaining specifically to the marking of the consignee’s or consignor’s name and address are located in §172.301(d) which reads:
(d) Consignee’s or consignor’s name and address. Each person who offers for transportation a hazardous material in a non-bulk package shall mark that package with the name and address of the consignor or consignee except when the package is—
(1) Transported by highway only and will not be transferred from one motor carrier to another; or
(2) Part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to one consignee.
If you’re like me, your first thought is, “consignee”? “consignor”? Huh? Well, the HMR answers one of your questions at §171.8:
Consignee means the person or place shown on a shipping document, package marking, or other media as the location to which a carrier is directed to transport a hazardous material.
Consignor is not clearly defined, but is consistently referred to within the HMR in the same manner as commonly-used in industry:
A person or company that consigns goods, merchandise, etc.
So, consignee is the intended destination of a hazardous material in transportation and consignor is its point of origin, ie. the offeror or shipper.
§172.301(d) requires the name and address of either the consignee (receiver) or consignor (shipper) to be marked on a non-bulk package. But, there are some exceptions, “…except when the package is…”. This particular marking is not required when the package is…
- Any type of package transported by highway by only a single motor carrier; or,
- The package is part of a load transported by truckload (highway), carload (rail), or freight container (vessel or air) and the entire load is shipped directly from one shipper to one receiver. A freight container (see definition below) could be used in the transportation of HazMat by air or vessel as well as highway or rail.
Freight container means a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.
As you can tell from this regulation, the PHMSA/USDOT wants information about either the shipper or the receiver of a hazardous material to be available on its non-bulk package during transportation. However, in situations where no person besides the shipper (consignor), original carrier, and the receiver (consignee) will come into contact with it, the PHMSA/USDOT is willing to forgo this requirement.
By the way, it’s pronounced: kuh n-sahy-ner or kon-sahy-nawr (consignor) and kon-sahy-nee (consignee).
If you are a consignor or consignee for shipments of hazardous materials, then you must provide triennial HazMat Employee Training for any employee involved in its handling. Please contact me for a free consultation.