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What are the Basic Rules for Shipping Papers?

Fot 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. Please see the 40 hour HAZWOPER training course for more info.

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
transportation;

• 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.

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