In the nerve-wracking post-9/11 climate in which we live, never has it been more important for those who handle and transport hazardous materials in the United States and Canada to do so in compliance â€” compliance with the DOTâ€™s 49 CFR (Code of Federal Regulations), Parts 100 through 185, the Hazardous Materials Regulations (HMR), and also the TDGRs (Transportation of Dangerous Goods Regulations), enforced by Transport Canada.
This article presents a simple, seven-step approach for staying compliant with the HMRs. (Although U.S. and Canadian authorities offer reciprocity, this article will mirror U.S. regulatory compliance.)
Step 1: Classification & Identification
The shipper (consignor) is responsible for the proper classification, or description, of hazardous materials. An easy way to remember the shipping description is using the acronym â€œSHIPâ€:
S â€“ shipping name â€” Assigned to the hazmat by the regulations, it is not a trade name, rather the name found in the Hazardous Materials Table, 49 CFR Â§172.101. Proper shipping names are listed in Column 2, with bold-faced text, and descriptions in italics.
H â€“ hazard class â€” This refers to the type of danger. There are nine classes, further divided into divisions. An example would be Division 1 of Class 6 written as â€œClass 6.1.â€ In addition, some materials possess multiple hazards. The primary class represents the greater risk during transportation. The subsidiary (AKA secondary) risk designates all other dangers. For example, METHANOL is flammable and toxic; therefore, in the hazmat table, it would read (in Column 3) â€œClass 3 (6.1)â€ or â€œ3 (6.1).â€
I â€“ identification number â€” A four-digit numerical code preceded by the letters â€œUNâ€ or â€œNA.â€ UN numbers are taken from the international standard, while â€œNAâ€ numbers are used for domestic transportation only, assigned by the DOT.
P â€“ packing group â€” This refers to the severity of the hazard. More specifically, Column 5 (PG) in the table contains Roman numerals I (great danger), II (medium danger) or III (minor danger).
Step 2: Packaging
Invariably, the only barrier between the hazardous material and the person carrying it is the package in which it resides. Packaging is divided into three basic groups, by size:
bulk is considered volumes over 119 gallons (450 L);
intermediate bulk containers (IBCs) have volumes between 119â€“793 gallons (450-3,000 L);
non-bulk, the most common packages, have internal volumes of 119 gallons (450 L) or less.
Non-bulk packaging is further classified as single, combination or composite packaging, per Â§171.8.
Step 3: Marking & Labeling The overt way of identifying hazmat is recognizing the shipping name, identification number, hazmat label(s) and UN marking on the package. Hazmat liquids also require orientation marks (as do dangerous goods shipped via air), as seen in Figure 1.
Step 4: Documentation Proper hazmat shipping paperwork is a critical part of the regulatory spectrum. Consider the scenario of a firefighter arriving at a tank-truck spill with placards torn off or covered, and an unconscious driver. Without placards, firemen are trained to look in the driver-side door pouch for the BOL (bill of lading). First responders will check the â€œS-H-I-Pâ€ contents, including the UN number on the far left of the BOL, then refer to his/her ERG (Emergency Response Guidebook) for proper response details. Also required on the BOL is a 24-hour emergency phone number.
Step 5: Placarding Think of placards as â€œlabelsâ€ for bulk (120+ gallons, 883+ pounds) hazmat carriage. Whether stationary storage tanks or mobile tankers cruising down your local highway, the DOT requires placards on all four sides. According to 49 CFR Â§172.332(c), placards must be durable, of specific sizes (at least 10.8â€ square-on-point) and affixed prior to loading. Placards must be removed following offloading. They may contain a four-digit identification code (e.g., 1075), text of the hazard (e.g., Flammable Gas), or simply a word like â€œDangerous.â€
Step 6: Loading The loading and unloading of hazardous materials is certainly a form of handling. What good are proper labeling, packaging and placards if Class 1.1 dynamite is placed adjacent to a pallet of blasting caps on a trailer? Therefore, 49 CFR details procedures for safe loading and segregation (see Â§177.848). Issues like securing and lashing of cylinders, not smoking, securing parking brake, and more, are covered.
Step 7: Reporting According to the HMRs, proper reporting of certain incidents like spills must be made immediately via phone, or routinely via written reports. Immediate reports include hazmat incidents during loading, unloading or temporary storage. The person in â€œphysical possession of the hazardous materialsâ€ has up to 12 hours to report the incident by calling the NRCâ€™s (National Response Center) toll-free number. Written reports require the use of DOT Form F 5800, and a copy must be retained for two years.