Hazardous Materials Transportation Guides
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HAZARDOUS MATERIALS DEFINITIONS
The following definitions have been abstracted from the Code of
Federal Regulations, Title 49, Transportation, Parts 100-199.
Refer to the referenced sections for complete details. Note: In
column (1), 49 CFR 172.101, Hazardous Materials Table, the (+)
fixes the proper shipping name and hazard class. The name and
class do not change whether the material meets or does not meet the
definition of that class. (49 CFR 172.101(b)(1))
HAZARDOUS MATERIAL - A substance or material, including a hazardous
substance, which has been determined by the Secretary of
Transportation to be capable of posing an unreasonable risk to
health, safety, and property when transported in commerce, and
which has been so designated. (See 49 CFR 171.8)
MULTIPLE HAZARDS - A material meeting the definition of more than one
hazard class and must be classed according to its position on the
list in 49 CFR 173.2(a).
For example, a material that meets the definition of a flammable
liquid and an irritating material would be classed as a flammable
liquid.
DOT HAZARD UN CLASS DEFINITION
CLASS
EXPLOSIVES An Explosive is any chemical compound,
mixture, or device which is designed to
function by explosion, that is
substantially instantaneous with the
release of gas and heat. Exception--such
compound, mixture, or device which is
otherwise specifically classified in Parts
171-180. (See 49 CFR 173.50)
CLASS A 1 Detonating. Maximum Hazard. The nine
types of Class A explosives are defined in
49 CFR 173.53.
CLASS B 1 Flammable Hazard. In general, functions by
rapid combustion rather than detonation.
Included are explosive devices such as
special fireworks, flash powders, etc. (49
CFR 173.88)
CLASS C 1 Minimum hazard. Small arms ammunition,
certain types of fireworks and various
types of manufactured articles containing
restricted quantities of Class A and/or
Class 11 explosives as components.
Included are common fireworks and various
types of small arms ammunition
manufactured articles which contain
restricted quantities of Class A or Class
B explosives. (49 CFR 173.100)
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DOT HAZARD UN CLASS DEFINITION
CLASS
BLASTING AGENT 1 Blasting Agent. A material designed for
blasting which has been tested in
accordance with 49 CFR 173.114(a)(b). It
must be so insensitive that there is very
little probability of: (1) accidental
explosion or (2) going from burning to
detonation. (49 CFR 173.114a(a))
GASES 2 Compressed Gas. Any material or mixture
having in-the-container an absolute
pressure exceeding NON-FLAMMABLE GAS 40
psi at 70' F, OR a pressure exceeding 104
psi at 130'F; or any liquid flammable
material having a vapor pressure exceeding
40 psi at 100'F. (49 CFR 173.300(a))
2 Non-liquified Compressed Gas - A gas
(other than gas in solution) which, under
the charged pressure, is entirely gaseous
at a temperature of 70'F. (49 CFR
173.300(c))
2 Liquefied Compressed Gas - A gas which,
under the charged pressure, is partially
liquid at a temperature of 70-F. (49 CFR
173.300(d))
2 Compressed Gas in solution - A non-
liquified compressed gas which is
dissolved in a solvent. (49 CFR
173.300(e))
2 Flammable Compressed Gas - Any compressed
gas meeting criteria as specified in 49
CFR 173.300(a) and (1)). This includes:
lower flammability limit, flammability
limit range, flame projection, or flame
propagation.
2 Nonflammable Gas - Any compressed gas
other than a flammable compressed gas.
FLAMMABLE LIQUID 3 Flammable liquid - Any liquid having a
flash point below 100'F. Authorized
methods to determine flashpoints are
listed in 49 CFR 173.115(d). For
exceptions, see 49 CFR 173.115(a).
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DOT HAZARD UN CLASS DEFINITION
CLASS
FLAMMABLE LIQUID 3 Pyrophoric Liquid - Any liquid that
ignites spontaneously in dry or moist air
at or below 130'F. (49 CFR 173.115(c))
COMBUSTIBLE LIQUID 3 Combustible liquid - Any liquid that does
not meet any other hazard class, other
than ORM-E, having a flash point at or
above 100'F. and below 200'F. For
exceptions, see 49 CFR 173.115(b).
Authorized methods to determine
flashpoints are listed in 49 CFR
173.115(d). Exceptions are found in 49 CFR
173.118(a).
FLAMMABLE SOLID 4 Flammable Solid - Any solid material
(other than an explosive) which under
normal transportation conditions is liable
to cause fires through friction or
retained heat from manufacturing or
processing. It can, be ignited readily and
burns so vigorously and persistently, as
to create a serious transportation hazard.
Included in this class are spontaneously
combustible and water reactive material.
(49 CFR 173.150)
4 Spontaneously Combustible Material (solid)
- A solid substance (including sludges and
pastes) which may undergo spontaneous
Treating or self-ignition under normal
transportation conditions. These
materials may increase in temperature and
ignite when exposed to air. (49 CFR 171.8)
4 Water Reactive Material (solid) - Any
solid substance (including sludges and
pastes) which react with water by igniting
or giving off dangerous quantities of
flammable or toxic gases. (49 CFR 171.8)
ORGANIC PEROXIDE 5 Organic Peroxide - Any organic compound
containing the bivalent -0-0- structure.
It may be considered a derivative of
hydrogen peroxide where one or more of the
hydrogen atoms have been replaced by
organic radicals. It must be classed as
an organic peroxide unless it meets
certain criteria listed in 49 CFR
173.151(a).
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DOT HAZARD UN CLASS DEFINITION
CLASS
OXIDIZER 5 An Oxidizer - A substance such as
chlorate, permanganate, inorganic
peroxide, or a nitrate, that yields oxygen
readily to stimulate the combustion of
organic matter. (49 CFR 173.151)
POISON A 2 Extremely Dangerous Poisons - Poisonous
gases or liquids--a very small amount of
the gas, or vapor of the liquid, mixed
with air is dangerous to life. (49 CFR
173.326)
POISON B 6 Less Dangerous Poisons - Substances,
liquid or solid (including pastes and
semi-solids), other than Class A Poisons
or Irritating Materials--so toxic (or
presumed to be toxic) to man that they are
a hazard to health during transportation.
(49 CFR 173.343(a))
IRRITATING MATERIAL 6 An Irritating Material - A liquid or solid
substance which, upon contact with fire or
air, gives off dangerous or intensely
irritating fumes. It does not include any
poisonous material, Class A.(49 CFR
173.381)
ETIOLOGIC AGENT 6 An Etiologic agent - A living micro-
organism (or its toxin) which causes (or
may cause) human disease, and includes
those agents listed in 49 CFR 72.3.(49 CFR
173.386)
RADIOACTIVE MATERIAL 7 Radioactive Material - Any material, or
combination of materials, that
spontaneously gives off ionizing
radiation. It has a specific activity
greater than 0.002 microcuries per gram.
(49 CFR 173.403)(See 49 CFR 173.403(a)
through (z) for details.)
CORROSIVE, MATERIAL 8 Corrosive Material - A liquid or solid
that causes visible destruction or
irreversible damage to human skin tissue
on contact. Also, it may be a liquid that
has a severe corrosion rate on steel. (See
49 CFR 173.240 (a) and (b) for details.)
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DOT HAZARD UN CLASS DEFINITION
CLASS
ORM- OTHER REGULATED MATERIALS
9 (1) Any material that may pose an
unreasonable risk to health, safety, and
property when transported in commerce; and
(2) does not meet any of the definitions
of the other hazard classes specified in
this subchapter, or (3) has been
reclassed an ORM (specifically or
permissively) according to this
subchapter. (49 CFR 173.500(a))
ORM-A 9 An ORM-A is material which has an
anesthetic, irritating, noxious, toxic, or
other similar property. If the material
leaks during transportation, passengers
and crew would experience extreme
annoyance and discomfort. (49 CFR
173.500(b)(1))
ORM-B 9 An ORM-B is material, (including a solid
when wet with water), the leakage of which
could cause significant damage to the
vehicle transporting it. Materials meeting
one or both of the following criteria are
ORM-it materials: (1) specifically
designated by name in 49 CFR 172.101
and/or (2) a liquid substance that has a
corrosion rate exceeding 0.250 inch per
year(IPY) on non-clad aluminum. An
acceptable test is described in NACE
Standard TM-01-69.(49 CFR 173.500(b)(2))
ORM-C 9 An ORM-C is material which has other
inherent characteristics not described as
an ORM-A or ORM-B, but which make it
unsuitable for shipment, unless properly
identified and prepared for
transportation. Each ORM-C material is
specifically named in 49 CFR 172.101. (49
CFR 173.500(b)(3))
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DOT HAZARD UN CLASS DEFINITION
CLASS
ORM-D 9 An ORM-D is a material such as a consumer
commodity which presents a limited hazard
during transportation due to its form,
quantity and packaging. It must be a
material for which exceptions are provided
in 172.101. Shipping descriptions
applicable to ORM-D materials are found in
49 CFR 172.101. (49 CFR 173.500(b)(4))
ORM-E 9 An ORM-E is a material that is not
included in any other hazard class but is
subject to the requirements of this
subchapter. Materials in this class
include: (1) HAZARDOUS WASTE and (2)
HAZARDOUS SUBSTANCES, as defined in 49 CFR
171.8. (49 CFR 173.500(b)(5))
THE FOLLOWING ARE OFFERED TO EXPLAIN SOME OF THE ADDITIONAL TERMS
USED IN PREPARATION OF HAZARDOUS MATERIALS FOR SHIPMENT. (49 CFR
171.8)
DOT TERM EXPLANATION
CONSUMER COMMODITY
A material that is packaged or distributed in a form intended
or suitable for sale through retail sales agencies. The
material is for use by individuals for personal care or
household use. This term also includes drugs and medicines.
(49 CFR 171.8)
FLASH POINT
The minimum temperature at which the flammable vapors of a
substance (in contact with a spark or flame) will ignite. For
liquids, see 49 CFR 173.115. ],or solids, see 49 CFR 173.150.
FORBIDDEN
A material that is prohibited from being offered or accepted
for transportation. This Prohibition does not apply if these
materials are diluted, stabilized, or incorporated in devices
AND they are classed in accordance with Part 173 of the
subchapter. (See 49 CFR 172.101 (d)(1)).
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DOT TERM EXPLANATION
HAZARDOUS SUBSTANCE
A material, including its mixtures and solutions, that: (1) is
listed in the Appendix to 172.101; (2) is in a quantity, in
one package, which equals or exceeds the reportable quantity
(RQ) listed in the Appendix to 49 CFR 172.101; (3) when in a
mixture or solution for radionuclides conform to the appendix
to 172.101, Table 2 is in a concentration by weight, which
equals or exceeds the concentration corresponding to the RQ of
the material as shown in the table of the 'hazardous
substance" definition in 49 CFR 171.8. This definition does
not apply to petroleum products that are lubricants or fuels.
(See 40 CFR 300.6.)
HAZARDOUS WASTE
Any material that is subject to the Hazardous Waste Manifest
Requirements or the U.S. Environmental Protection Agency
specified in the CFR Title 40, Part 262. For answers to
questions regarding EPA hazardous waste regulations, call 1-
800-424-9346 in Washington, DC.
LIMITED QUANTITY
The maximum amount of a hazardous material authorized for
specific labeling and packaging exceptions. Consult the
section applicable to the particular hazard class. See 49 CFR
173.118, 173.118(a), 173.153, 173.244, 173.306, 173.345, and
173.364.
* THIS HANDOUT IS DESIGNED AS A TRAINING AID FOR ALL INTERESTED
PARTIES WHO MAY BECOME INVOLVED WITH HAZARDOUS MATERIALS. IT DOES
NOT RELIEVE PERSONS FROM COMPLYING WITH THE DEPARTMENT OF
TRANSPORTATION'S HAZARDOUS MATERIALS REGULATIONS. SPECIFIC
CRITERIA FOR HAZARD CLASSES AND RELATED DEFINITIONS ARE FOUND IN
THE CODE OF FEDERAL REGULATIONS (CFR), TITLE 49, PARTS 100-199.
Note:This material may be reproduced without special permission
from this office.
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GUIDE FOR HAZARDOUS MATERIALS
SHIPPING PAPERS
USE OF GUIDE - This Guide is designed for in-house use when
reviewing hazardous material shipping paper requirements. However,
this document should not be used to determine compliance with the
U.S. DOT Hazardous Materials Regulations (HMR).
1. DEFINITIONS
A. Shipping Paper - (49 CFR 171.8) A shipping paper is a
shipping order, bill of lading, manifest, or other
shipping document serving a similar purpose and
containing the information required by 49 CFR 172.202,
172.203 and 172.204.
B. Hazardous Waste Manifest - (40 CFR 262.20) A hazardous
waste manifest is a document (shipping paper) on which
all hazardous waste is identified. A copy of the
manifest must accompany each shipment of waste from the
point of pick-up to the destination. For waste
shipments, the hazardous waste manifest satisfies DOT
shipping paper requirements, if all DOT requirements for
shipping papers are met. (49 CFR 172.205)
2. SHIPPER'S RESPONSIBILITY - (49 CFR 172.200(a)) The person
offering a hazardous material for transport has the
responsibility to Properly prepare the shipping paper. (See
also 49 CFR 173.22.)
3. GENERAL ENTRIES ON SHIPPING PAPERS - (49 CFR 172.201)
A. Contents - When describing a hazardous material on a
shipping paper, that description must conform to the
following requirements
(1) When a hazardous material and other materials are
both described on the same shipping paper, the
hazardous material description entries:
(a) Must be entered first, or
(b) Must be entered in a contrasting color (or
highlighted in a contrasting color - for
reproduced copies of the shipping paper only),
or
(c) Must be identified by the entry "X" placed
before the proper shipping name in a column
captioned "IIM." The "X" may be replaced by
"RQ" (Reportable Quantity), if appropriate.
(See Figure I on following page.)
(2) The required shipping description on the original
shipping paper and all copies must be legible and
printed (manually or mechanically) in English.
(3) The required description may not contain any code or
abbreviation, unless it is specifically authorized
or required, such as "UN," United Nations, "NA,"
North America, or "Ltd Qty," Limited Quantity.
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(4) A shipping paper may contain additional information
concerning the material provided that the
information is not inconsistent with the required
description. The additional information must be
placed after the basic description required by 49
CFR 172.202(a)(4).
(a) When appropriate, the entries "IMO" or "IMO
Class" may be entered immediately before or
immediately following the class entry in the
basic description.
(b) If a material meets the definition of more than
one hazard class, the additional hazard
class(es) may be entered after the hazard class
in the basic description.
NOTE: The International Civil Aviation Organization (ICAO)
issues the "Technical Instructions for the Safe Transport of
Dangerous Goods by Air" for the international transportation of
goods by air.
The International Maritime Organization (IMO) issues the
"International Maritime Dangerous Goods Code (IMDG)" for the
international transportation of hazardous materials by water.
The terms "dangerous goods" and "hazardous materials" are
considered synonymous.
B. Name of Shipper - A shipping paper for a shipment by
water must contain the name of the shipper.
C. Emergency Response Telephone Number - A shipping paper
must contain an emergency response telephone number, as
required by 49 CFR, Subpart G of Part 172.
4. HAZARDOUS MATERIALS DESCRIPTION - (49 CFR 172.202) The
shipping description of a hazardous material on a shipping
paper must include the following information:
A. Proper Shipping Name - The name prescribed for material
in 49 CFR 172.101 Hazardous Materials Table or 172.102
Optional IIMT MAY NOT BE ABBREVIATED. (49 CFR 172.202 (a)
(1)).
B. The Hazard Class of the Material - The class prescribed
for material in 49 CFR IIM Table 172.101 or 172.102
Optional IIMT. (See 49 CFR 172.202(a)(2).)
C. The Identification Number - The number prescribed in the
IIM Table 172.101 or 172,102 Optional table for the
material (preceded by "UN" or "NA," as appropriate). (49
CFR 172.202(a)(3))
D. The Total Quantity By Weight (net or gross, as
appropriate) or volume, including the unit of measure, of
the hazardous material, except for empty packagings,
cylinders of compressed gases, and packagings of greater
than 110 gallon capacity. (49 CFR (172.202 (a)(4))
E. Except as otherwise provided in the regulations, the
basic description specified in 172.202 (a)(t),(2), and
(3) must be in the sequence shown. For example:
"Acetone, Flammable liquid, UN 1090." (49 CFR
172.202(b)).
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F. The total quantity of the material covered by one
description must appear before or after (or both before
and after) the basic description. (49 CFR 172.202(c)).
(1) Abbreviations may be used to specify the type of
packaging and units of measure of the total
quantity. For example: 10 ctns. Paint, flammable
Liquid, UN 1263, 500 lbs. (49 CFR 172.202(c)(1)).
(2) Type of packaging and destination marks may be
entered in any appropriate manner before or after
the basic description. (49 CFR 172.202(c)(2)).
5. ADDITIONAL DESCRIPTION REQUIREMENTS (49 CFR 172.203) (ALL
MODES)
A. Exemptions - Each shipping paper issued in connection
with shipment made under an exemption must bear the
notation "DOT-E" followed by the exemption number
adjacent to the description to which the exemption
applies. (49 CFR 172.203 (a))
B. Limited Quantities - Descriptions for materials offered
as "Limited Quantities" must include the words "Limited
Quantities" or "Ltd Qty" following the basic description.
(49 CFR 172.203(b))
C. Hazardous Substances (49 CFR 172.203(c))
(1) If the proper shipping name (for a material that is
a hazardous substance) does not identify the
hazardous substance by name, the following shall be
entered, in parentheses, in association with the
basic description:
(a) Name of the hazardous substance from the
Appendix to the 49 CFR 172.101 Hazardous
Materials Table, or
(b) For waste streams, the waste stream number (A
"waste stream" is a hazardous waste liquified,
sludge, solid, gas] continuously generated from
a manufacturing process. Such waste will be
listed in either 49) CFR 261.31 or 40 CFR
261.32, and will be assigned an EPA waste
stream number-), or
(c) For wastes exhibiting an EPA characteristic of
ignitability, corrosivity, reactivity, or EPA
toxicity the letters "EPA" followed by the word
"ignitability," "corrosivity," "reactivity," or
"El" toxicity" or the corresponding "I)"
number, as appropriate.
(2) The letters "RQ" (Reportable Quantity) shall be
entered on the shipping paper either before or after
the basic description required by 49 CFR 172.202 for
each hazardous substance.(See definition in 49 CFR
171.8)
Example: "RQ, Cresol, Corrosive UN 2076"; or
"Hazardous Substance, Solid, n.o.s., ORM-E, NA 9188
(Adipic Acid), RQ."
D. Radioactive Materials - For additional description
requirements for radioactive materials, refer to 49 CFR
172.203(d).
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GUIDE FOR MARKINGS
USE OF GUIDE - This guide was prepared as an aid to shippers and
carriers of hazardous materials. It does not contain or refer to
all of the DOT requirements for marking. For specific details,
refer to appropriate Section of Title 49, Code of Federal
Regulations (CFR), Parts 100-199.
MARKING - means placing on the outside of a shipping container, one
or more of the following: the proper shipping name, hazard class,
identification number, instructions, caution, and/or weight.
Marking also includes any required specification marks on the
inside or outside shipping container.
DESCRIPTIVE INFORMATION
I. GENERAL REQUIREMENTS (49 CFR 172.300-172.304)
A. Unless Specifically Excepted, all packages of hazardous
materials must be marked with:
1. The proper shipping name.
2. UN or NA Identification number of the contents (49
CFR 172.101 or 49 CFR 172.102, Hazardous Materials
Tables.)
3. if the inhalation toxicity of any material in a
package falls within the criteria specified in 49
CFR 173.3a(b)(2), the package shall be marked
"Inhalation Hazard" in association with the required
label(s).
4. The name and address of either the consignee or
consignor.
B. All markings must be:
1. Durable and in English, printed or affixed to the
surface of the package or on a label, tag or sign.
2. On a background of a sharply contrasting color, and
unobscured by labels or attachments.
3. Placed away from other marking that could reduce
effectiveness.
II. SPECIFIC REQUIREMENTS
A. HAZARDOUS SUBSTANCES (49 CFR 172.324)
1. For a package of 110 gallons or less that contains a
hazardous substance that is not identified by the
proper shipping name, one of the following must be
entered, in parentheses, in association with the
proper shipping name:
a. Name of the hazardous substance from Appendix
to 49 CFR 172.101, or
b. For waste streams, the waste stream number or
c. For waste exhibiting an EPA characteristic of
ignitability, corrosivity, reactivity, or EPA
toxicity, the letters EPA followed by
"ignitability", or "corrosivity", or
"reactivity", or "EPA toxicity", or the
corresponding "D" number, as appropriate.
2. Each package with a capacity of 110 gallons or less
that contains a hazardous substance must display
"RQ" in association with the proper shipping name.
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B. LIQUID HAZARDOUS MATERIALS (49 CFR 172.312)
1. Must be packed with the closures of the inside
packaging in the upright position.
2. Must have marking "THIS SIDE UP" or "THIS END UP" on
the outside packaging.
3. Should use arrow symbol on the outside packaging to
show upright orientation of packages. (See ANSI
Standard MH6.11968 "Pictorial Marking for Handling
Goods.")
C. CONTAINERS-OVERPACKS
1. The outside container (overpack) must be marked in
accordance with 49 CFR 173.25.
D. CONTAINER-CYLINDERS
1. All cylinders must be marked in accordance with 49
CFR 173.34 and 49 CFR 173.301 through 173.306.
2. Reinspected and Retested Cylinders must be marked in
accordance with 49 CFR 173.34(e)(6).
III. TANKS
A. PORTABLE TANKS (49 CFR 172.326 and 49 CFR 172.332) -
Portable tanks must be marked with:
1. Proper shipping name - in letters at least 2 inches
high and on two opposite sides.
2. Identification number - UN or NA (United Nation or
North American) identification number on:
TWO OPPOSITE SIDES (near proper shipping name) on
tanks of less than 1,000 gallons capacity; on EACH
SIDE AND EACH END on tanks of more than 1,000 gallon
capacity.
3. Name of owner or lessee.
4. All inlets and outlets (except safety relief valves)
when carrying compressed gases (DOT-51).
5. Whether or not the inlets and outlets communicate
with vapor or liquid (49 CFR 178.245-6(b)).
B. CARGO TANKS - HIGHWAY (49 CFR 172.328) - Cargo tanks must
be marked with:
1. Identification number - (49 CFR 172.101)
2. In addition to identification numbers, cargo tanks
transporting compressed gases must be marked with:
(a). Proper shipping name or appropriate common name
such as "Refrigerant Gas." Letters must be at
least 2 inches high on each end and each side.
(49 CFR 172.101, 172.102, and 172.328(c)(1)(2))
(b). Inlets and outlets (except safety relief
valves) shall be marked to designate whether
the inlets and outlets communicate with vapor
or liquid, when the tank is filled to its
maximum permitted filling density. (49 CFR
178.337-9 for DOT MC 331 tanks)
NOTE: When ID numbers are displayed on placards, orange panels
are not required. When ID numbers are displayed on orange panels,
or white square-on-point display configurations, appropriate
placards are ALSO REQUIRED. For materials in hazard classes for
which placards are specified and identification numbers are
required, but for which ID numbers may not be displayed on the
placards required for the material (49 CFR 172.334(a)), ID numbers
must be displayed on orange panels or on plain white square on-
point display configuration in association with the placard. ID
numbers on white square-on-point display configuration are
considered markings and the display is not a placard. (49 CFR
172.332, 172.334, 172.336)
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C. TANKS CARS (49 CFR 172.330) - Certain cars are required
to be marked on each side and each end (49 CFR 172.332
and Parts 173 and 179 for specific details). If required
to be marked, they must include:
1. Proper shipping name or appropriate common name in
letters at least 4 inches high with at least a 5/8"
stroke.
2. Identification numbers - Display the appropriate
number(s) (49 CFR 172.101) on placards, orange
panels or white square-on-point display
configurations.
3. The accurate name of the contents contained in the
tank.
NOTE: For requirements for multi-unit tank car tanks, see
49 CFR 172.330(d)-(f).
IV. BULK PACKAGING - (other than portable tanks, cargo tanks,
tank cars and multi-unit tank car tanks) 49 CFR 172.331
A. Includes packages meeting the following criteria: (see 49
CFR 171.8)
1. Internal volume greater than 118.9 gallons (450
liters) for liquids, or
2. A capacity greater than 881.8 pounds (400 kilograms)
for solids, or
3. A water capacity greater than 1000 pounds (453.6
kilograms) for a gas as defined in 49 CFR 173.300.
B. Mark packages as prescribed in 49 CFR 172.332 or
172.336(b), as appropriate, with the identification
number specified in 172.101 when authorized:
1. On two opposite sides for packages of 1000 gallons
(3785.4 liters or 133.7 cubic feet) or less
capacity.
2. On each side and end for packages greater than 1000
gallons (3785.4 liters or 133.7 cubic feet)
capacity. Identification numbers shall be displayed
on orange panels or specified placards, or when
appropriate, on white square-on-point display
configurations having the same outside dimensions as
a placard.
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V. RADIOACTIVE MATERIALS (49 CFR 172.310) - In addition to any
other marking required by Subpart D of 49 CFR 172 (Marking),
each package must be marked as follows:
A. Gross weight must be marked on containers weighing over
110 pounds.
B. "TYPE A" or "TYPE B"(as appropriate) in letters at least
1/2 inch high.
C. "USA," must follow the specification markings or package
certification on export shipments.
VI. OTHER REGULATED MATERIALS (ORM's) (49 CFR 172.316)
A. Place the appropriate ORM designation immediately
following or below the proper shipping name on at least
one side or end of the package.
B. Marking must be within a rectangular border -
approximately 1/4 inch in size on each side of
"ORM______" (ORM designation).
NOTE: By these markings, the shipper certifies that the
material is properly described, classed, packaged, marked, labeled,
and in proper condition for transportation. The shipper's
certification is still required on the shipping paper (172.204).
When ID numbers are required, they must be displayed on either
orange panels (172.332 (b)) or on a plain white square-on-point
configuration having the same dimensions as a placard.
OTHER MARKING REQUIREMENTS
I. REQUALIFIED CONTAINERS - DRUMS (marked by reconditioner).
Some steel containers in the DOT Series (DOT 17C, 17E, and
17H) may be qualified for reuse by a DOT-registered
reconditioner of drums. The drums are stripped of labels,
exemption numbers, and other markings. They are reconditioned
to meet 49 CFR 173.28 (m) and marked with the appropriate
assigned registration number.
II. CYLINDERS & TANKS - (Marked with inspection and/or retest
date). Reusable cylinders, portable tanks, cargo tanks and
tank cars must be either visually inspected or retested at
periodic intervals. The date of requalification must be on
the container. (See 49 CFR 173.24, 173.31, 173.32, 173.33, and
173.34.)
III CARGO HEATERS - Cargo heaters authorized for use with
flammable liquid or gas must be marked in accordance with 49
CFR 177.834 (1)(1)(2)(E) and (F).
IV. MOTOR VEHICLES - A carrier may not move a transport vehicle
containing hazardous material unless the vehicle is marked in
accordance with Part 172 or unless an emergency exists. (See
49 CFR 177.823.)
3-4
SPECIFICATION CONTAINERS
I. GENERAL - Specification containers must be marked with DOT
specification numbers under which the containers are made (49
CFR Parts 178 and 179). 'Me manufacturer's name and address
or symbol must be registered with the Associate Administrator
for Hazardous Materials Safety. Duplicate symbols are not
authorized.
II. MARKINGS - All containers must comply with the marking
requirements of 49 CFR 173.24, Parts 178 and 179. Exceptions
for Canadian and other import/export situations are found in
49 CFR 171.12 and 171.12a.
NOTE: For certain containers, specific detailed information
(such as original test date information and type of material) are
required. (See Parts 178 and 179.) As a final check before offering
a shipment for transportation, visually inspect the shipment.
This handout does not contain all the marking requirements. It is
designed as a guide only. For details on markings, consult the
Code of Federal Regulations, Title 49, Parts 100-199.
This publication may be reproduced without special permission from
this office.
Revised: February 1991
3-5
GUIDE FOR
HAZARDOUS MATERIALS SHIPPERS
USE OF GUIDE - This Guide is presented as an aid to shippers of
hazardous materials. It does not contain or refer to all of
the DOT requirements for shipping hazardous materials. For
specific details, refer to all of the DOT requirements for
shipping hazardous materials. For specific details, refer to
the Code of Federal Regulations (CFR), Title 49,
Transportation, Parts 100-199.
The following is offered as a step-by-step procedure to aid in
compliance with the applicable DOT Regulations.
STEP 1 - DETERMINE THE PROPER SHIPPING NAME - The shipper must
determine the proper shipping name of the materials as listed in
the Hazardous Materials Table, 49 CFR 172.101, Column (2).
STEP 2 - DETERMINE THE HAZARD CLASS OR CLASSES
A. Refer to the Table, 49 CFR 172.101, Column (3) and locate
the hazard class of the material.
B. If more than one class is shown for the proper shipping
name, determine the proper class by definition.
C. If the materials have more than one hazard, classify the
material based on the order of hazards in 49 CFR 173.2.
STEP 3 - SELECT THE PROPER IDENTIFICATION NUMBERS
A. Refer to the Table, 49 CFR 172.101, Column (3a) and
select the Identification Number (ID) that corresponds to
the proper shipping name and hazard class.
B. Enter the ID number(s) on the shipping papers and display
them, as required, on packagings, placards and/or orange
panels.
STEP 4 - DETERMINE THE MODE(S) OF TRANSPORT TO ULTIMATE DESTINATION
A. As a shipper, you must assure yourself that the shipment
complies with various modal requirements.
B. The modal requirements may affect the following: (1)
Packaging; (2) Quantity per Package; (3) Marking; (4)
Labeling; (5) Shipping papers; (6) Certification.
STEP 5 - SELECT THE PROPER LABEL(S) AND APPLY AS REQUIRED
A. Refer to the Table, 49 CFR 172.101, Column (4 ) for
required labels.
B. For details on labeling refer to: (1) Additional Labels,
49 CFR 172.402; (2) Placement of Labels 49 CFR 172.406;
(3) Packagings (Mixed or Consolidated), 49 CFR 172.404(a)
and (b); (4)Packages Containing Samples, 49 CFR
172.402(h); (5) Radioactive Materials, 49 CFR 172.403;
and, (6) Authorized Label Modifications, 49 CFR 172.405.
4-1
STEP 6 - DETERMINE AND SELECT THE PROPER PACKAGES
A. Refer to the Table, 49 CFR 172.101, column 5(a) for
exceptions and Column (5b) for specification packagings.
Consider the following when selecting an authorized
package: Quantity per package; Cushioning material, if
required; Proper closure and reinforcement; Proper
pressure; Outage; etc. as required.
B. If packaged by a prior shipper, make sure the packaging
is correct and in proper condition for transportation.
STEP 7 - MARK THE PACKAGING (INCLUDING OVERPACKS)
A. Apply the required markings (49 CFR 172.300); Proper
shipping name and ID number, when required (49 CFR
172.301); Name and address of Consignee or Consignor (49
CFR 172.306).
B. For details and other required markings, see 49 CFR
172.300 through 172.338.
STEP 8 - PREPARE THE SHIPPING PAPERS
A. He basic requirements for preparing shipping papers
include: Proper Shipping name; Hazard class; ID number;
Total quantity; Shipper's certification; and emergency
response telephone number.
B. Make all entries on the shipping papers using the
information required and in proper sequence (49 CFR
172.202).
C. For additional requirements, see 49 CFR 172.200 through
172.205.
STEP 9 - CERTIFICATION
A. Each shipper must certify by printing (manually or
mechanically) on the shipping papers that the materials
being offered for shipment are properly classified,
described, packaged, marked and labeled, and in proper
condition for transportation according to the applicable
DOT Regulations (49 CFR 172.204).
B. For surface shipments; see 49 CFR 172.204(a) and (b); for
air shipments, see 49 CFR 172.204(c).
STEP 10 - LOADING, BLOCKING AND BRACING -
When loading hazardous materials into the transport vehicle or
freight container, each package must be loaded, blocked and braced
in accordance with the requirements for mode of transport.
A. If the shipper loads the freight container or transport
vehicle, the shipper is responsible for the proper
loading, blocking, and bracing of the materials.
B. If the carrier does the loading, the carrier is
responsible.
STEP 11 - DETERMINE THE PROPER PLACARD(S) -
Each person who offers hazardous materials for transportation
must determine that the placarding requirements have been met.
A. For Highway, unless the vehicle is already correctly
placarded, the shipper must provide the required
placard(s) and required ID number(s) (49 CFR 172.506).
B. For Rail, if loaded by the shipper, the shipper must
placard the rail car if placards are required. (49 CFR
172.508)
C. For Air and Water shipments, the shipper has the
responsibility to apply the proper placards.
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STEP 12 - HAZARDOUS WASTE/HAZARDOUS SUBSTANCE
A. If the material is classed as a hazardous waste or
hazardous substance, most of the above steps will be
applicable.
B. Pertinent Environmental Protection Agency Regulations are
found in the Code of Federal Regulations, Title 40, Part
262.
AS A FINAL CHECK AND BEFORE OFFERING THE SHIPMENT FOR
TRANSPORTATION, VISUALLY INSPECT YOUR SHIPMENT. THE SHIPPER SHOULD
ENSURE THAT EMERGENCY RESPONSE INFORMATION IS ON THE VEHICLE FOR
TRANSPORTATION OF HAZARDOUS MATERIALS.
NOTE: This material may be reproduced without special
permission from this office.
Revised: February 1991
4-3
GUIDE FOR
HAZARDOUS MATERIALS CARRIERS
USE OF GUIDE - This Guide was prepared as an aid to carriers of
hazardous materials. It does not contain or refer to all of the
DOT requirements for transporting hazardous materials. For
specific details, refer to the Code of Federal Regulations (CFR),
Title 49, Transportation, Parts 100-199.
Basically, all "for hire" carriers and all "private carriers" are
subject to the same or at least very similar DOT hazardous
materials regulations.
Containerization and other modern freight handling procedures
frequently prevent initial carriers from making physical
inspections of the freight. It is more difficult for interline
(secondary) carriers to determine the physical condition of freight
or regulatory compliance. Carriers, therefore, must frequently
accept the word of shippers as to the suitability of the package
and the accuracy of the material description. Therefore, it is
very important to carefully review the shipping documents including
the shippers' certification. Always visually inspect the transport
vehicle or freight container for leaks or potential problems.
Careful attention to the following subject areas will,aid in
complying with the "Carrier Regulations":
I. DETERMINE EMPLOYEE QUALIFICATIONS
"It is the duty of each motor carrier to comply with the prescribed
regulations and to thoroughly instruct employees in relation
thereto." [Refer to CFR, Title 49, 174.7 (Rail); 175.20 (****r);
176.13 (Water); and 177.800(b) (Highway)].
This means that carriers are required to make certain that
employees who have any responsibility for receiving, processing or
transporting hazardous materials are thoroughly instructed. They
must know the applicable regulations that apply to their job
functions. The following suggestions will help to meet this
requirement:
A. Identify all personnel who have hazardous materials
transportation responsibilities.
B. Determine what additional instruction or training each
needs (if any).
C. Assure that those needing instruction receive the
instruction.
D. Maintain records of training.
E. Periodically review training needs and maintain the
required expertise.
II. DETERMINE CONDITION OF TRANSPORT VEHICLE
A. Make certain that the cargo space is suitable for
loading. It should be free of nails and other protruding
sharp objects.
B. Make certain that the vehicle is suitable for the
material to be loaded. It must be in compliance with
applicable carrier safety and hazardous materials
regulations, as well.
5-1
III. MAY THE SHIPMENT BE ACCEPTED FOR TRANSPORT?
"No person may accept for transportation any shipment of hazardous
material that is not in accordance with Parts 171, 172, and 173."
[Refer to CFR, Title 49, 174.3 (Rail); 175.3 (Air); 176.3 (Water);
177.801 (Highway)].
To comply with this provision, a carrier must:
A. Determine that the shipping papers are prepared in proper
format and are accurate and complete. At minimum, they
must include the proper shipping name, hazard class, ID
number, quantity, emergency response telephone number,
and consignee (or consignor) name and address.
B. Obtain a proper shipper's certificate (unless excepted).
C. Determine that proper placard(s) and ID number(s) are
displayed, when required.
D. Determine that emergency response information is on the
vehicle.
When practical, a carrier should also determine that:
A. Authorized packagings are used and that they are in
proper condition for transportation.
B. Each package is properly marked and labeled, when
required.
C. The freight is adequately blocked and braced to prevent
movement and/or damage in transit.
IV. IS THE SHIPMENT TO BE INTERLINED?
A. Properly prepare the material so that the secondary
carrier will accept it from you. This is particularly
important for intermodal and international shipments.
B. Modal requirements may affect the following: (1)
Packaging; (2) Quantity per package; (3) Marking;
(4)Labeling; (5) Shipping papers; (6) Certification.
V. CARRIER LOADED FREIGHT
When the carrier loads the transport vehicle, make certain that:
A. Documentation matches the freight.
B. Materials are loaded in accordance with 49 CFR 177.848.
C. Poisons are not loaded with foodstuffs (unless excepted).
D. Damaged or leaking packages are not loaded.
E. Freight is properly blocked and braced to prevent damage
in transit.
F. Proper placards and ID numbers are displayed, when
required.
G. Required documentation is furnished by the
driver/pilot/conductor/captain.
VI. HAZARDOUS WASTE /HAZARDOUS SUBSTANCE
A. When the material is classified as a hazardous waste or
hazardous substance, there are additional registration,
identification, and documentation regulations as stated
in 49 CFR 172.205 and 172.324.
B. Pertinent Environmental Protection Agency Regulations are
found in the Code of Federal Regulations, Title 40, Part
262.
5-2
VII. INCIDENT REPORTS
The carrier who transports hazardous materials (including hazardous
waste and hazardous substances) is responsible for reporting
requirements. Most incidents involving unintentional releases of
hazardous materials in transportation must be reported to DOT.
Detailed criteria concerning telephonic and/or written reports are
published in CFR, Title 49, Sections 171.15 and 171.16.
NOTE: This material may be reproduced without special
permission from this office.
Revised: February 1991
5-3
INDICATORS OF HAZARDOUS MATERIALS
SHIPMENT VIOLATIONS
The enforcer, shipper, container manufacturer, or carrier may use
this partial listing of items to spot check for compliance with the
DOT Hazardous Materials Regulations. Included in this listing are
indicators only and not necessarily violations in and of
themselves.
The hazardous materials regulations for shippers are found in the
Code of Federal Regulations, Title 49, Parts 171, 172, 173, 178,
179 and 180. These Parts of 49 CFR contain general requirements
and communication regulations. This list may be used as a guide
when looking for discrepancies or making a compliance inspection.
Areas to consider include, but are not limited to: classification,
packaging, marking, labeling, placarding, loading, blocking and
documentation. When using this information, remember it is
designed to be used as a guide only and does not cover all aspects
of the regulations.
I. PROPER SHIPPING NAME AND HAZARD CLASS
A. Inaccurate designation of hazard class.
B. Failure to properly classify material having more than
one hazard. (49 CFR 173.2)
C. Inaccurate description and/or proper shipping name for
material being shipped (49 CFR 172.101 and 172.102)
D. Omission of technical name or names of material following
n.o.s. description of material. CFR (49 CFR 172.203(k))
E. When required, the letters "RQ" not displayed in
association with the proper shipping name. (49 CFR
172.203(c)(2))
F. Missing emergency response information and telephone
number.
II. PACKAGING (CONTAINERS IN GENERAL)
A. Use of DOT specification packages not authorized for the
material being shipped.
B. Use of containers that are leaking. (49 CFR 173.24)
C. Manufacturing and marking containers as meeting a DOT
specification when they do not meet the specification.
D. Packaging exceeding maximum quantity limitations for
materials.
E. Packages improperly marked.
F. Offering for shipment improperly packaged material.
G. Consignee or consignor's name marking omitted from
packaging. (49 CFR 172.306)
H. Identification numbers omitted on packagings. (49 CM
172.301)
III. CONTAINERS (MISCELLANEOUS)
A. STEEL
1. Labeled containers with no DOT specification
marking. (Commonly found violations are 5 gallon 29
gauge metal pails and 5 gallon rectangular cans).
2. Packages of hazardous materials with temporary
repairs (e.g. damaged, sealed with tape, putty,
chewing gum, or screws).
3. Labeled containers in improper condition, i.e.,
dented, rusted or corroded. (NOTE: Some of these are
judgmental decisions).
4. Specification marking is illegible on labeled
containers.
6-1
5. Labeled reused containers marked "NRC" (look for old
date of manufacturer, dents, rust, and paint
layers).
6. Labeled reused containers marked "STC" and/or 17C,
17E, and 17H with no reconditioner's marking.
7. Labeled reused containers with a reconditioner's
marking that is not a DOT 17C, 17E, or 17H
container.
8. Labeled 55 gallon open-head drums with 2 rolling
hoops and/or less than 5/8 inch ring bolt, non-drop
forged ring lugs, and/or "lever lock' ring closures.
(Good possibility of non-DOT specification).
9. Imported drums marked as meeting the DOT Hazardous
Materials Regulations.
B. FIBERBOARD BOXES
1. Boxes with no DOT specification marking, for
example, when inside packaging$ are larger than the
"limited quantity" exception for the commodity and
specification packaging is required.
2. Boxes marked with DOT specification marking which
are poorly constructed (i.e., gaps, uneven closures,
seams and joint separation).
3. If inner flaps do not meet, are fill-in pieces used
to fill void?
4. Boxes damaged by water.
5. Improperly closed boxes (look for masking tape,
cellophane tape, and string).
6. Non-DOT specification fiberboard box used in lieu of
specification container, when required.
C. POLYETHYLENE PACKAGINGS
1. Open-head polyethylene packagings used for materials
not authorized- to be in them.
2. Illegible marked packagings.
3. Leaking containers offered for transportation.
4. When poison is shipped, is the container marked
"POISON"?
D. FIBER DRUMS
1. Non-DOT specification fiber drums.
2. Fiber drums constructed of materials weaker than
required by the specification.
3. Use of fiber drums marked DOT-21P without inside
polyethylene liner.
4. Using fiber drums marked "STC" more than once for
shipping hazardous materials.
5. Damaged fiber drums.
6. Improper markings on containers for the commodity
being shipped.
E. CYLINDERS
1. Reuse of single-use cylinders such as DOT
Specification 39.
2. Cylinders in use beyond test date.
3. Cylinders in improper condition:
a. No valve protection
b. Bulge inside
c. Dented or corroded
d. Defective valve
4. Cylinders refilled by other than the owner of the
cylinder and without the permission of the owner.
5. Cylinders improperly marked, e.g. duplication of
serial numbers.
6-2
6. Cylinders offered for transportation without proper
identification of contents.
7. Identification symbols not registered with the
Department of Transportation.
8. Illegible cylinder markings.
F. PORTABLE TANKS
1. Name of owners or lessee omitted on tank.
2. No labels and/or placards displayed on tank
containing hazardous materials.
3. No identification number displayed on the placard or
on an orange panel. (I 172.326)
G. CARGO TANKS (QUALIFICATION AND MAINTENANCE) (49 CFR
180.401-417)
1. Using a cargo tank without proper identification of
contents.
2. Improperly marked, e.g. size of marking or not
marked in contrasting color.
3. Omission of the marking "QT" (Quenched and Tempered
Steel or "NQT" (other than Quenched and Tempered
Steel), when required on cargo tanks. (49 CFR
172.328(d) and 173.315)
4. Omission of identification number on placard or
orange panel.
5. Test Date Markings missing or out-of-date.
IV. MARKING OF CONTAINERS (49 CFR 172.300-172.338)
A. No proper shipping name and/or ID number on the
container. (49 CFR 172.301)
B. No name and address of consignee or consignor on the
container. (49 CFR 172.306)
C. No DOT Exemption number on containers shipped under DOT
Exemptions. (49 CFR 173.22(a)(1)(iv))
D. Container marking not in a contrasting color. (49 CFR
172.304)
E. Gross weight not marked on radioactive materials packages
weighing over 110 pounds. (49 CFR 172.310)
F. Container of liquid hazardous material not marked on
outside "THIS END UP" or "THIS SIDE UP." (49 CFR 172.312)
G. Reconditioned drums improperly marked. (49 CFR 173.28)
H. USA not included as part of the DOT Specification
markings for radioactive materials packages destined for
export. (49 CFR 172.310)
I. Portable tanks not marked with proper name of the
hazardous material. (49 CFR 172.326)
J. Omission of identification numbers (when required on
placard or orange panel. (49 CFR 172.332)
K. Omission of marking of INHALATION HAZARD, when required.
(49 CFR 172.301)
V. LABELING (49 CFR 172.400-172.450)
A. No labels on outer container to represent mixed packaging
of hazardous materials. (49 CFR 172.404)
B. Label on the container not consistent with the hazard
class on the shipping paper. (49 CFR 172.400)
C. Use of obsolete labels. (49 CFR 172.407)
D. Color and/or size of label does not meet standard. (49
CFR 172.407)
E. No label on shipments destined for air transport. (49 CFR
172.402)
F. Labeling containers not authorized to be labeled. (49 CFR
172.400)
G. No label on "LIMITED QUANTITIES" offered for air
transportation. (See appropriate section 49 CFR Part
173.)
6-3
H. Less than two radioactive materials labels (White I,
Yellow 11, or Yellow III on containers (two opposite
sides). (49 CFR 172.403)
VI. PLACARDING AND VEHICLE MARKINGS (49 CFR 172.500-172.558)
A. Failure to placard vehicle requiring placarding. (49 CFR
172.504)
B. Failure to use more than one kind of placard to indicate
more than one hazard class of material loaded within
vehicle. (49 CFR 172.504 and 172.505)
C. Over 640 cubic foot freight container containing
hazardous material not placarded. (49 CFR 172.512)
D. Placards not applied to four sides of transport vehicle.
(49 CFR 172.514)
E. Placarding material not authorized to be placarded. (49
CFR 172.502)
F. Omission of identification number (when required) on
placard or orange panel.
VII. SHIPPING PAPERS (49 CFR 172.200 - 172.205)
A. No proper shipping name and/or classification of
hazardous material entered on shipping papers. (49 CFR
172.202)
B. Proper shipping name and/or classification abbreviated.
(49 CFR 172.202)
C. No certification for shipment. (49 CFR 172.204)
D. No wordage for "LIMITED QUANTITY" or "Ltd Qty" on
shipments excepted from specification packaging and
labeling. (49 CFR 172.203)
E. No DOT Exemption number on shipments moving under DOT
Exemption. (49 CFR 172.203)
F. Color of label indicated in lieu of the proper hazard
class. (49 CFR 172.202)
G. Inaccurate format for hazardous materials description on
shipping papers, e.g., HM entries not first, in
contrasting color or no HM column. (49 CFR 172.201)
H. No identification number (UN or NA on shipping paper. (49
CFR 172.202)
I. Missing emergency response information and telephone
number.
NOTE: This material may be reproduce without special permission
from this office.
Revised: February 1991
6-4
