What I should know

All shipping paper entries must be legible and printed in English. No unauthorized abbreviations are permitted. If more than one page, each page must be numbered consecutively, and the first page must specify the total number of pages.

Package orientation markings are to be affixed or pre-printed on at least two opposite sides so as to show the proper package orientation for the closure(s) to be in the upright position. The words "THIS SIDE UP" or "THIS WAY UP" may also be displayed on the top of the package or Overpack

Note 1: Must be used on combination packagings and Overpacks containing liquid dangerous goods, excluding flammable liquids in inner receptacles of 120 mL or less: the words "Dangerous Goods" may be inserted on the label below the line.

The documentation or paper containing the hazardous materials information required by the regulations. It must be retained for one year by the offeror and carrier. The shipping paper must contain the basic description plus any required additional descriptions or entries. The basic description includes the proper shipping name, the hazard class or division, the identification number (ID No.), and the packing group (PG), if any is assigned.

The total quantity of the material, which is part of the shipping description, must be shown before and/or after the basic description. The total quantity must include the unit of measurement, such as liters (gallons) or kilograms (pounds), and can be gross or net.A hazardous material and nonhazardous material, not regulated by the HMR, may be placed on the same shipping paper. However, the hazardous material entries must be entered first, or highlighted or entered in a contrasting color, or identified by an "X" in a column captioned "HM". Instead of an "X", the letters "RQ" may be entered in this column to identify a hazardous substance. "RQ" indicates the material is a hazardous substance, that is, a material with a reportable quantity in one package.Sometimes an additional entry is required, and the description is not complete unless the required additional entry has been entered in the proper place. For example, the DOT has granted exemptions or relief from certain hazardous materials regulations for specific packagings or shipping procedures. If shipment is made under an exemption, the shipping paper must bear the letters "DOT-E" followed by the assigned exemption number.

A hazardous material may be shipped as a limited quantity. If so, the words "Limited Quantity" must be on the shipping paper following the basic description.

For hazardous substance shipments, the letters "RQ" must be entered on the shipping paper. Enter "RQ" before or after the basic description for each Hazardous Substance.

Some proper shipping names of hazardous substances do not identify the hazardous substance by name, such as an N.O.S. entry. For example, RQ, Environmentally Hazardous Substances, Liquid, N.O.S., 9, UN3082, PG III, (Amitrole), 454 kg. In this case, Amitrole must be in parentheses. If a hazardous material is described on a shipping paper by one of the N.O.S. proper shipping names listed in 172.203(k)(3), the technical name must be shown in parentheses in association with the N.O.S. proper shipping name.

An emergency response telephone number must be entered on the shipping paper immediately after each hazardous material description or if the telephone number applies to all hazardous materials listed on the shipping paper, entered only once, in a clearly visible location, and with an indication that the number is for emergency response information.

The emergency response telephone number must be monitored at all times while the hazardous material is in transportation, including storage incidental to transportation. The contact person must be knowledgeable of the hazard characteristics, emergency response information, and incident mitigation information for the hazardous material listed on the shipping paper, or have immediate access to someone who has that knowledge. The emergency response telephone number must be that of the shipper or an agency or organization capable of, and accepting responsibility for, providing current information.

Emergency response documents must contain information on the hazardous material, immediate hazards to health, risks of fire or explosion, immediate precautions to be taken in the event of an accident or incident, immediate methods for handling fires, immediate methods for handling spills or leaks, and preliminary first aid measures.

The required emergency response information must be available for use away from the package of hazardous material. It must be printed in English and presented in any one of the following ways: on the shipping paper, in a document such as a material safety data sheet (MSDS) along with the shipping paper, or in a separate document such as an emergency response guidance document. The hazardous material carrier must maintain and carry the emergency response information in the same manner as the shipping paper.

The shipping paper must have a written, signed certification that the hazardous materials are properly offered for transportation, according to the HMR (Hazardous Materials Regulations).

The term "marking" as used in the HMR, means applying the required information to the outside of shipping containers. This includes the descriptive names of the hazardous material plus any required instructions and/or cautions.

The requirements for marking of packages is contained in 49 CFR, Subpart D, Part 172. The basic marking requirement consists of the proper shipping name and identification number of the hazardous materials contained in the package.

Markings should be durable, in English, and not obscured by other markings or labels. Depending on the material there may be additional marking requirements. For non-bulk packaging, technical names must be marked in parenthesis in association with the proper shipping name if required by §172.203(k). Identification numbers are not required for ORM-D and limited quantities.

Bulk packaging requirements are in section 172.302. Identification Numbers must be on each side and each end for packages 3785 L (1000 gals) or more and for cylinders permanently mounted on tube trailer motor vehicle. Identification

Numbers on two opposing sides for packages less than 3785 L (1000 gals). Technical names are not required for bulk packages. You may not offer or transport a container unless the HM markings apply to the material contained in the package. There is an exception for empty containers if; (1) In a vehicle or freight container, the package is not visible, and is loaded and unloaded by the shipper or consignee, or (2) The markings are securely covered during transport. The following is a listing of additional marking requirements:

Bulk packagings other than portable tanks, cargo tanks, tank cars, and multi-tank car tanks Identification number markings

General labeling requirements are contained in 49 CFR, Subpart E, Part 172. Each person who offers for transportation or

transports a hazardous material shall ensure the package is properly labeled. There are a number of exceptions to the labeling requirements contained in §172.400a. Prohibited labeling is contained in §172.401. The following is a list of additional requirements:

There is a separate section for each of the labels that gives an example of the label and describes the label.

General placarding requirements are contained in 49 CFR, Subpart F, Part 172. Each person who offers for transportation any hazardous materials subject to the HMR shall comply with the applicable placarding requirements (see §172.500). Placarding is not required for infectious substances, ORM-D materials, limited quantities, small quantity shipments, combustible liquids in non-bulk packages and the domestic transportation of Class 9 materials. Placards may not be displayed on any packaging, freight container, unit load device, motor vehicle or rail car unless the placard represents a hazardous material loaded into or onto the conveyance unless the shipment is in accordance with the TDG Regulation, the IMDG Code, or the UN Recommendations.

General placarding requirements are contained in §172.504. Each bulk packaging, freight container, unit load device, transport vehicle, or rail car containing any quantity of hazardous materials must be placarded on each side and each end with the placards specified in Tables 1 and 2. Section 172.504 contains a number of notes and exceptions to these requirements. When two or more Table 2 materials are contained in the same transport vehicle, the "Dangerous" placard may be used instead of the specific placard required for each hazard class. However, when 1,000 kg (2,205 lbs.) or more of a single category of HM is loaded on a transport vehicle at one loading facility, the placard specified for that material must be displayed. Section 172.504(c) contains an exception from the placarding requirement for shipments that contain less than 454 kg (1001 pounds) of Table 2 materials. A frequent problem encountered involves the 1001 lb exception. The 1001 lbs. is aggregate gross weight. Aggregate gross weight is the total weight of all hazardous materials and its packaging loaded on a single transport vehicle. There are additional requirements for placarding such as:

NOTE: FOR SPECIFIC REQUIREMENTS FOR PREPARATION OF SHIPMENTS YOU MUST USE THE MOST CURRENT EDITION OF 49 CFR.

A properly completed bill of lading (shipping papers) must be in the transport vehicle and immediately accessible to the driver. This document must contain the following information:

By January 1, 2004, shippers would need to make a special determination that any packaging containing hazardous materials meets all applicable air transport requirements. In addition, shippers would need to signify this decision by a special marking on each packaging and will apply also to limited quantities and consumer commodity packaging (ICAO Meeting).

That a new IATA-only "liner" requires that any combination packaging containing liquids in Classes 3, 4 or 8, or Divisions 5.1, 5.2 or 6.1 - regardless of packing group or of the mode, results in a requirement for a liner for a great many packages where ICAO (or DOT) would not require the liner (Air Transport) Jan/Feb 2002

When using V-marked packaging, the DOT rules and related DOT correspondence clearly imply that more inner packagings and larger inner packagings may be used than were used in the design qualification test for the basic packaging. But special weight restriction limitations apply.

The training regulations apply to all haz-mat employees as defined in 49 CFR 171.8. This term includes individuals employed by a haz-mat employer and who, in the course of their employment, load, unload or handle these materials; prepare them for transportation, i.e., package them; operate vehicles used to transport them; determine if containers, drums or other packaging are qualified for use in the transportation of these materials; or are responsible for safety in the transportation of hazardous materials.

Hazmat employee training must include general awareness and safety training, as well as function-specific training. Each employer must provide its employees with a range of training consistent with the nature of the job performed. The general awareness training, in the words of 49 CFR 172.704, is to "provide familiarity with the requirements of this subchapter and to enable them to recognize and identify hazardous materials consistent with the hazard communication standards of this subchapter." Safety training includes emergency response instruction in workplace exposure protection measures, the proper procedures for handling packages, and how to avoid accidents. Safety training includes emergency response instruction in workplace exposure protection measures, the proper procedures for handling packages, and how to avoid accidents.

On 01/1/07 the US Department of Transportation issued a new final rule titled "Hazardous Materials in Intrastate Commerce." This rule extends federal authority to the intrastate transportation of hazardous materials, and creates several exceptions for transporters of hazardous materials. These exceptions include:

•	use of non-specification packaging in intrastate transportation;

•	transportation of hazardous agricultural chemicals by farmers.

A MOT is a hazardous material, other than a hazardous waste, that is carried on a motor vehicle:

•	for the purpose of protecting the health and safety of the vehicle operator or passengers (e.g., self-contained breathing apparatus or insecticide);

•	for the purpose of supporting the operation or maintenance of a motor vehicle including its auxiliary equipment (e.g., engine starting fluid or spare wet batteries); or

•	by a private motor carrier, including a vehicle operated by a rail carrier, in direct support of a principal business that is other than transportation by motor vehicle (e.g., cylinders of compressed gas carried by a plumber for use with a cutting torch).

The MOT exceptions apply to both interstate and intrastate carriers. A hazardous material transported in compliance with the MOT exception is not subject to additional hazardous material regulation.

Non-bulk liquid or solid HM packaged as MOT must be marked with the proper DOT shipping name or the common name of the material including the letters "RQ" if the package contains a reportable quantity of a hazardous substance. Compressed gas cylinders must be marked and labeled as required in the hazardous material regulations (HMR). A MOT that is properly classed, packaged, and transported, does not require shipping papers, package labeling (except cylinders of compressed gasses), or placarding of vehicles.

•	Hazard Classes 3 (flammable liquids), 8 (corrosives), 9 (miscellaneous hazardous material), and ORM-D (Consumer Commodities)

•	Hazard Divisions 2.1 (flammable gases), 2.2 (nonflammable gases), 4.1 (flammable solids), 5.1 (oxidizers), 6.1 (poison liquids or solids).

Note: HM that is self-reactive or poisonous by inhalation is specifically excluded from the MOT provisions. Check the HM regulations to confirm that a particular product is authorized as a MOT. MOT Packaging Requirements.

Materials of trade are restricted to the following package sizes based on packing groups:

•	Packing Group I: packaging not over 0.5 kg (1 pound) or 0.5 L (1 pint)

•	Packing Groups II or III, and ORM-D: packaging not over 30 kg (66 pounds) or 30 L ( 8 gallons)

Cylinders of compressed gas must be no larger than 100 kg (220 pounds) gross weight each, and must conform to the qualification and use requirements of the HMR.

Packages of MOT must be leak tight, sift proof, closed, and secured in the vehicle against movement and damage. The package should be the original manufacturer's package, or one of equal or greater strength.

Gasoline transported as MOT must be packaged in metal or plastic containers that meet either the UN packaging standards or OSHA requirements.

No more than 200 kg (440 pounds) aggregate gross weight of MOT may be transported on a single vehicle (e.g., a tow truck driver could carry a 150 pound cylinder of division 2.1 acetylene and a 150 pound cylinder of 2.2 oxygen, two 8 gallon cans of gasoline weighing 60 pounds each and 20 pound battery and use the MOT exception).

Drivers transporting MOT must be aware of the presence of MOT in their vehicle, must be informed of the requirements of the MOT rule, and be able to identify the HM to truck inspectors or emergency response personnel.

One type of bulk packaging may be transported as a MOT. A tank with a capacity of 1500 L (400 gallons) or less and containing a Class 9 HM in a dilute mixture not exceeding a 2% concentration, may be transported as a MOT. This exception is designed to allow Class 9 pesticides or herbicides that would qualify for the MOT exception in a small package, to be mixed with water in small cargo or portable tanks and moved as a materials of trade. These bulk packages must be marked on two opposite sides with the ID number of the material on orange panels or white square on point devices.

HM-200 prohibits shipment of hazardous waste as a MOT. The Office of Motor Carrier Services received a written interpretation from US DOT stating that wastes excepted from the Uniform Hazardous Waste Manifest requirements may be carried as MOT if the waste is an allowed hazard class or division, and is packaged, marked, secured, and transported in conformance with the requirements of Code of Federal Regulations, title 49, section 173.6.

Many electric utilities and used-oil haulers use test kits containing very small quantities of Division 4.3, Dangerous When Wet materials. HM-200 allows the transportation of test kits containing Packing Group II or III material in packaging having a gross capacity not exceeding 30 ml (1 ounce).