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:
- The chemical identity of the hazardous material: its technical name.
- The name of a category or group of chemicals, e.g. “Alcohols, n.o.s.”
- The intended use of the material, e.g. “Resin Solution”.
- 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.
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