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What are the Basic Rules for Shipping Papers?
For HAZMAT certification, a shipping paper for hazardous materials transportation is any document that contains the information required to describe the hazardous material being transported. It may include a shipping order, a bill of lading, a hazardous materials manifest, or any other type shipping document serving a similar purpose and containing the required information. Only in the case of hazardous wastes is there a prescribed shipping paper format – the hazardous waste manifest.
The basic rule for shipping papers is that if you transport any quantity of any hazardous material, a properly prepared shipping paper must accompany the shipment. This includes materials identified as hazardous substances, hazardous wastes, and marine pollutants. The basic rules for describing and identifying hazardous materials in transportation are quite simple: Mark the package, label the package, prepare a shipping paper with all the information, including emergency response information, and placard the vehicle. Now let’s look at the exceptions to the basic rules regarding shipping papers that cause the most confusion among people handling hazardous materials.
There are certain shipments of hazardous materials that do not require description as hazardous materials on a shipping paper.
HAZMAT Certification Shipping Paper Exceptions
Some of the more common exceptions include:
• Hazardous materials with an ‘A’ in column 1 of the HMT offered or intended for transportation only by highway, rail, or vessel, unless the material is identified as a hazardous substance, a hazardous waste, or a marine pollutant and then it is regulated in all modes of
• Hazardous materials with ‘W’ in column 1 of the HMT offered or intended for transportation only by highway, rail, or air, unless the material is identified as a hazardous substance, a hazardous waste, or a marine pollutant and then it is regulated in all modes of transportation;
• Small quantity shipments prepared in accordance with §173.4;
• Certain agricultural shipments prepared and transported in accordance with §173.5.
• Materials of Trade shipments prepared in accordance with §173.6;
• Certain U.S. Department of Energy and U.S. Department of Defense shipments prepared in accordance with §173.7; and
• Shipments of ORM-D, unless transported by air, in accordance with §172.200(b) (3).
What Are Some Examples?
Say you are shipping Dibromodifluoromethane by vessel, with no intention that it will make any leg of its journey by air. Assume that this Dibromodifluoromethane is not waste.
– Since it does not appear in Table 1 or Table 2 of Appendix A, it is not a hazardous substance.
– Since it does not appear in the List of Marine Pollutants, it is not a marine pollutant.
– Finally, since it is identified by the letter “A” in Column 1 of the HMT, and since it is not being offered or intended for transportation by air, it meets the first shipping paper exception: “Shipments with a letter “A” in column 1 of the HMT, if shipped by highway, rail, or vessel only”.
– So this shipment of Dibromodifluoromethane, under the circumstances presented, would not require description as a hazardous material for hazmat certification on a shipping paper.
The first step in HAZMAT certification is filling out a shipping paper correctly is to look in the Hazardous Materials Table (HMT) §172.101, and find the entry that most appropriately describes the material you are shipping. Information used to describe a hazardous material on a shipping paper is known as the Basic Description. Information for the HAZMAT Certification Basic Description consists of the Identification Number in Column 4; the Proper Shipping Name in Column 2; the Hazard Class or Division in Column 3; and the Packing Group in Column 5. If a material has one or more subsidiary hazards, they are identified in Column 6. Subsidiary hazards must also be listed with the Basic Description. By using the information provided in the HMT, you can correctly describe the hazardous materials shipment.
Columns 1 and 7 provide HAZMAT certification codes that may indicate additional information about the material you are shipping. For example, a “G” in Column 1 indicates that the Proper Shipping Name listed must be further identified by the addition of a “technical name” placed in parentheses. The chemical manufacturer or the material safety data sheet should provide this information.
New! The new OSHA/GHS Hazard Communication (HAZCOM) regulation may impact the shipment of HAZMAT intems in the near future. OSHA issued a final rule on this regulation that will affect many industries. Stationary containers that require HAZMAT labeling may require the new pictograms to be attached.
49 CFR § 172.704:
(a) Hazmat certification employee training must include the following:
(1) General awareness/familiarization training. Each hazmat employee shall be provided general awareness/familiarization training designed to provide familiarity with the requirements of this subchapter, and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of this subchapter.
(2) Function-specific training.
(i) Each hazmat employee shall be provided function-specific training concerning requirements of this subchapter, or exemptions issued under subchapter A of this chapter, which are specifically applicable to the functions the employee performs.
(ii) As an alternative to function-specific training on the requirements of this subchapter, training relating to the requirements of the ICAO Technical Instructions and the IMDG Code may be provided to the extent such training addresses functions authorized by §§ 171.11 and 171.12 of this subchapter.
(3) Safety training. Each hazmat employee shall receive safety training concerning — (i) Emergency response information required by subpart G of part 172;
(ii) Measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the work place, including specific measures the hazmat employer has implemented to protect employees from exposure; and
(iii) Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials.
(4) Security awareness training. No later than the date of the first scheduled recurrent training after March 25, 2003, and in no case later than March 24, 2006, each hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. After March 25, 2003, new hazmat employees must receive the security awareness training required by this paragraph within 90 days after employment. This is a HAZMAT certification requirement and must be accomplished to receive your certification.
THE FIVE TYPES OF HAZMAT CERTIFICATION TRAINING REQUIRED BY DOT GENERAL AWARENESS/FAMILIARIZATION TRAINING: Training that provides familiarity with the general requirements of the HMR and enables the hazmat employee to recognize and identify hazardous materials. All hazmat employees must receive general awareness training.
FUNCTION-SPECIFIC TRAINING: Training that provides a detailed understanding of HMR requirements applicable to the function(s) performed by the hazmat employee. Each hazmat employee must be trained on the specific functions they are required to perform.
SAFETY TRAINING: Training that covers the hazards presented by hazardous materials, safe handling, emergency response information, and methods and procedures for accident avoidance. All hazmat employees must receive this training.
SECURITY AWARENESS TRAINING: Training that provides a general understanding of the security risks associated with hazardous materials transportation and the methods designed to enhance transportation security. This training should include methods on how to recognize and respond to possible security threats. All hazmat employees must receive this training.
IN-DEPTH SECURITY TRAINING: Training that provides a detailed understanding of a company’s security plan including company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach and the organizational security structure. This training must be provided to hazmat employees who handle or perform regulated functions related to the transportation of the materials covered by the security plan or who are responsible for implementing the security plan.