Document 3QbDYndo86bx73vDX0N6Z45R6

ABDOO130663 of The Transportation of Hazardous Materials t( - ------1 - ------ ^ A complete, step by step Guide to the Transportation of Hazardous Materials, Wastes and Substances Under the U.S. Department of Transportation's Hazardous Material Regulations as published in HM-181 and HM-126C ^- - -- * Gary J. Groman ABD0013G664 of The Transportation of Hazardous Materials * -^ A complete, step by step Guide to the Transportation of Hazardous Materials, Wastes and Substances Under the U.S. Department ofTransportation's Hazardous Material Regulations as published in HM-181 and HM-126C fc .... ^ Gary J. Groman ABDOO130665 Copyright 1991 by GSI Computer Services, Inc. All rights reserved. No part of this work may be reproduced or transmitted in any form by any means, electronic or mechanical, including but not limited to photocopying and recording, or by any information storage or retrieval system without permission in writing from the author. The author does not make any warranty or representation, expressed or implied, with respect to the accuracy, completeness, or utility of the information contained in this document; nor does the author assume any liability with respect to the use of or reliance upon, or for damages resulting from the use of or reliance upon, any information, procedure, conclusion, or opinion contained in this document. ABDOO130666 This book is respectfully dedicated to: My God and my Lord to whom I owe all. My wife Lois who is the love of my life, my partner, and the most precious of God's many bless ings to me. My mother-in-law, Della McCue, whose daily life is an illustration of the true meaning of love, motherhood, and Christ-like living. My mom, Eleanor, my children Basil, Tom, Mary, and Becky; my grand children Basil Paul, Brant Patrick, and Mishay; and my brothers and sisters Galyn, Leta, Linus and Joan. They are my family. No man could ask for more. My students to whom I have always given my best and from whom the joys and meaning of my life's work have flowed. Those who realize that we are what we think and will make an effort to fill their minds with: "whatever is true, whatever is honorable, whatever is right, whatever is pure, whatever is lovely, whatever is of good repute, if there is any excellence and if anything worthy of praise, let your mind dwell on these things." Philippians 4:8 ABDOO130667 TABLE OFCONTENTS Introduction Hazardous Materials Exposures- Int- 1 Specific Hazardous Materials Safety Regulations- Int- 2 Actual Delay- Int- 2 Fines and Penalties- Int- 2 Civil- Int- 2 Criminal- Int- 2 Embarrassment- Int- 3 Bottom Line=Safety- Int- 3 THE A, B, C's OF REGULATORY ORGANIZATION- Int- 4 A Reasons for knowing How Regulations Are Organized- Int- 4 B. What is 49 CFR?- Int-4 G Relationship Between Title, Chapter, Sub Chapter, and Part- Int- 4 D. Keys to Everyday Use- Sections and Paragraphs- Int- 4 Sections- Int- 4 Paragraphs- Int- 5 E. Sub Parts- Int- 5 THE A, B, C's OF USING THE 172.101 TABLE-1 A Key to Compliance B. Column (1)- Symbols- 1 C. Column (2)- Proper Shipping Name-1 D. Column (3)- Class or Division- 2 E. Column (4)- Identification (UN or NA) Number- 2 F. Column (5)- Packing Group- 3 G. Column (6)- Labels- 3 H. Column (7)- Special Provisions- 3 I. Column (8)- Packaging Authorizations- 3 Column (8A)- Exceptions- 3 Column (8B)- Non Bulk Packagings- 4 Column (8C)- Bulk Packagings- 4 J. Column (9)- Quantity Limitations-4 Column (9A)- Passenger- 4 Column (9B)- Cargo Aircraft- 4 K. Column (10)- Vessel Stowage Requirements- 4 Column (10A)- Vessel Stowage- 4 Column (10B)- Other Provisions- 4 Classification Terminology- 5 Class or Classification- 5 Commercially Pure- 5 Hazard Class- 5 Hazardous Material- 5 Division- 5 Mixture- 6 Packing Group- 6 Primary Hazard- 6 Solution- 6 Subsidiary Hazard- 6 Technical Name- 7 l ABDOO130668 Technically Pure- 7 THE A, B, C's OF CLASSIFICATION- 7 A Technically Pure Materials Specifically Identified by Their Technical Name- 7 B. Mixtures, Solution, and Materials Not Specifically Identified by Their Technical Name- 8 Technically (Commercially Pure)- 8 Single Class Mixtures- 8 Multiple Class Mixtures-9 GSI 49 CFR Class/Division Reference Table-10 THE A, B, C's OF PROPER SHIPPING NAME DETERMINATION A General Rule- 11 1. Chemical Name-11 2. Generic Chemical or Usage Name- 11 3. General Hazard Class Name- 11 B. Specifically Listed Materials Mixture Rule- 12 C. Hazardous Waste Proper Shipping Names- 13 D. Proper Shipping Names For Certain Hazardous Substances- 13 E. Italics and Other Exceptions- 14 THE A, B, C's OF THE TECHNICAL (n.o.s.) NAME RULE-15 A Technical Name Rule- 15 B. Three (3) Types of Entries- 15 1. Technically Pure- Not Listed- 15 2. Mixture or Solution- One Hazard-One Material- 16 3. Multiple Classed Materials or Mixtures- Two or More Hazardous Materials- 16 THE A, B, C's OF HAZARDOUS SUBSTANCES-17 A EPA Hazardous Substance- 17 B. Hazardous Substance Relationship Between U.S. DOT and EPA- 17 G DOT Definition of Hazardous Substance- 17 D. How To Determine Whether or Not Its A DOT Hazardous Substance- 18 E. If It Is It Is Regulated as a Hazardous Material- 19 F. Specific Additional DOT Requirements- 19 G. Carrier Discharge Notification- 20 H. 40 CFR Warning- 20 THE A, B, C's OFHAZARDOUS WASTE IDENTIFICATION FOR TRANSPORTATION-21 A 49 CFR Definition- 21 B. When Does 40 CFR Part 262 Require a manifest- 21 G 40 CFR Definition of Solid Waste- 21 D. When is Material Discarded- 21 E. 40 CFR Definition of Hazardous Waste-21 1. Listed-21 2. Exhibits Characteristics- 22 F. Exclusions- 23 THE A, B, C's OF PACKAGING TERMINOLOGY- 25 A Packaging- 25 1. Combination- 25 Inner- 25 Outer- 25 2. Single-25 3. Composite-25 u ABDOO130669 B. Package- 25 C. Overpack- 26 THE A, B, C'S OFPACKAGING-27 A Determine Quantity Per Package To Be Shipped- 27 B. Select the PackagingAuthorization Section- 27 C. Packaging Selection- 28 D. General Packaging Considerations- 28 E. UN Specification Package Indications and Codes- 29 F. UN Specification vs Non Specification Packaging- 30 G. UN Performance Oriented Packaging (POP) Test- 31 H. Exceptions-31 1. Limited Quantity-31 2. Small Quantity- 32 3. Other- 32 THE A, B, C's OF MARKING- 35 A Proper Shipping Name- 35 Hazardous Wastes- 35 B. Technical Name- 35 G Identification Number- 35 D. Name and Address- 35 1. Hazardous Wastes- 36 E. Orientation Markings- 36 F. Hazardous Substances- 37 G. Packaging Specification Marks- 37 H. Poisonous (Division 6.1) Hazardous Materials- 37 L Exemption Packaging- 37 J. Radioactive Materials- 38 K. Overpack- 38 L. ORM-D Designation- 38 M. Class 1 EX-Number- 38 N. Prohibited Markings- 38 O. Marking Specifications- 38 THE A, B, C*s OF LABELING- 39 A 172.101 Table Label-39 B. Subsidiary Risk (Hazard) Labeling- 40 C. Label Placement- 41 D. Prohibited Labeling- 42 F. Other Labels- 42 1. Cargo Aircraft Only- 42 2. Radioactive Materials- 42 3. Empty-42 DOT Label Chart With Color Pictures- Appendix IV THE A, B, C's OF SHIPPING PAPERS- Introduction- 43 A Biggest Source Of Violation Activity and Shipment Delay- 43 B. Use By Emergency Response Personnel- 43 C. Definition of- 43 ill ABDOO130670 D. DOT vs "Normal" Shipping Paper- 44 E. General Applicability- 44 F. General Requirements- 44 G. Prohibited Entries- 45 THE A, B, C's OF THE BASIC DESCRIPTION (I72.202)-45 A Proper Shipping Name- 45 B. Technical Name- 45 C. Hazard Class- 46 D. Identification Number- 46 E. Packing Group- 46 F. Required Sequence- 46 G. Quantity of Material- 46 H. Emergency Response Telephone Number- 47 Sub Part G Emergency Response Information- Appendix II THE A, B, C's OF ADDITIONAL DESCRIPTION REQUIREMENTS-47 A DOT Exemptions- 47 B. Limited Quantity- 47 G Hazardous Substances- 48 D. Dangerous When Wet- 48 E. Poisons- Inhalation Hazard- 48 F. Hazardous Wastes- 49 G. Residue Last Contained-51 THE A, B, C's OF CERTIFICATION- 53 A Shippers Certification- 53 B. Signature- 53 C. Form of Certification- 53 D. No Certification Required- 53 THE A, B, C's OF PLACARDING- 55 A Placarding Selection (KIS Method)- 54 B. Placarding Exceptions- 54 1. 454 kg (10011b) Exception-55 2. Dangerous Placard- 56 3. Residue- Non Bulk- 56 4. Other Exceptions- 56 5. Applicability- 56 G Placarding Display- 57 D. Shipper Carrier Responsibility- 58 E. What is to Be Placarded and How Many- 58 F. Prohibited Placarding- 58 G. Placard Specifications- 59 DOT Placarding Chart with Color Pictures- Appendix IV THE A,B,C'S OF THE CLASS 3 TO COMBUSTIBLE EXCEPTION A What is It?-61 B. Advantages-61 C. Caution-61 iv (0691) ABDOO130671 THE A,B,C'S OF THE CONSUMER COMMODITY EXCEPTION A. What is a Consumer commodity?- 62 B. The Four Step Consumer Commodity ORM Reclassification Exception- 62 C. General Effect of Reclassification-64 D. Specific Effects of the Consumer Commodity ORM-D Exception- 64 E. Consumer Commodity, ORM-D "Retail Outlet" Exception- 66 F. Domestic Exception Only- 66 APPENDICES Appendix I- UN Performance Oriented Packaging Appendix II- Introduction to Emergency Response Information Under Sub Part G of49 CFR Appendix III- Listing of U.S. DOT Designated Packaging Certification Agencies Appendix IV- DOT Labeling-Placard Chart Appendix V- Metric Conversion Chart v (0691) ABDOO130672 INTRODUCTION Why Arc Materials That Are Not Hazardous Transported? Generally the transportation system is used to move non hazardous materials from Point A to Point B to meet the needs of the person or organization (Shipper) shipping the materials. These needs are as different as the filling of a customer's order or the movement of raw materials to where they are needed for production or other internal needs of the Shipper. As a general rule these materials are accompanied by documentation describing them, packaged to make sure they get to where they are going in good condition, and are handled in a manner that ensures the safety of Shipper and Carrier personnel, the general public, and the environment. Why Are Hazardous Materials Transported? Most shipments of Hazardous Materials are transported for the same reason that non Hazardous Materials are transported, to move them from Point A to Point B to meet the needs of the Shipper. Hazardous Materials are transported for various reasons such as to customers as finished products and internally as raw materials to manufacture products, for use as fuels, or as Hazardous Wastes for treatment or disposal to name a few. As is the case with non Hazardous Material shipments. Hazardous Materials shipments are accompanied by documentation describing them, packaged to make sure they get to where they are going in good condition and without releasing their contents while in the transportation system, and are handled in a manner that ensures the safety of Shipper and Carrier personnel, the general public, and the environment. = FOURHAZARDOUS MATERIALS EXPOSURES = S-Specific Safety Regulations A-Actual Delay F-Fines and Penalties E-Embarrassment to Company, Industry, or Self FIGURE 1 SAFE- The Four Hazardous Materials Exposures The primary difference between Hazardous Materials and non Hazardous Materials shipments is not in the basic objective of the shipment, to move it from Point A to Point B or in the need to identify, document, package and transport the shipments safely. It is in HOW Hazardous Materials are identified, packaged, documented, stored and transported. The transportation of Hazardous Materials or Dangerous Goods, as they are called in international transportation, is governed by specific governmental regulations requiring that Hazardous Materials be identified, packaged, and transported in a specific wav. This results in the exposure ofthe Shippers and Carriers of Hazardous Materials to four (4) things with which the Shippers and Carriers of non Hazardous Materials are not normally faced. These four exposures are summarized under SAFE in Figure 1 above and will be discussed individually starting on the next page. Intro-1 (0691) O 1991 GSl Computer Services Inc., Branson, MO 65616 Reprinted with All rights reserved- ABDOO130673 l ^Specific Hazardous Materials Safety Regulations- Shipments of Hazardous Materials are subject to a specific set ofHazardous Materials Transportation Regulations published by the U.S. Department of Transportation (49 CFR Parts 171-180). These regulations contain detailed instructions on how Hazardous Materials have to be Identified, Packaged, Marked, Labeled, Documented, and Placarded. Shipments not in compliance with the applicable regulations may not be Offered or Accepted for transportation. GSI CR: The ABC's of Regulatory Organization, Int-4 2 @rtual Delay- Shipments ofHazardous Materials that are not in compliance with the Hazardous Materials ^ Regulations may not be Offered or Accepted for Transportation (49 CFR 171.2(a)) or Transported within the transportation system (49 CFR 171.2(b)). Ifa shipment is found within the transportation system and it is not in compliance with the applicable regulations it will, in most cases, be delayed. In addition carrier acceptance inspections, special loading and compatibility requirements, enforce ment inspections while they are in the transportation system, and the natural curiosity, worry and concern that carrierand enforcement personnel have when a Hazardous Material is being shipped can result in the delay ofthe shipment. Tj 0mes and Penalties- In addition to resulting in the delay ofthe shipment, shipments ofHazardous Materials not in compliance with the applicable regulations can subject the Shipper, Forwarder, and Carrier, as appropriate, to Civil Penalties ofup to $25,000 per violation or Criminal Penalties of up to $500,000, imprisonment ofup to five (5) years, or both (49 USC 1809). Civil Penalty- Civil Penalties are usually imposed when the Hazardous Materials regulations are not followed. This can result when something is not done that the regulations require to be done such as marking the correct Proper Shipping Name on a package, labeling etc.. It can also result when something was done that the regulations prohibit such as putting a Placard on a vehicle that does not contain Hazardous Materials. The act or failure to act speaks for itselfand there is no requirementthat the violation be intentional orthat the person committing the violation even know there are Hazardous Materials Regulations in existence. Generally, ifa person Offers or Accepts a material for transportation and that material is regulated as a Hazardous Material and it's not in compliance with the Hazardous Materials Regulations, one or more violations has occurred regardless ofwhether or not the persons intended to violate the Hazardous Materials Regulations or even knew they existed. It's the same as speeding. The act speaks for itself. In most cases the fact that we did not intend to speed does not change the result. A ticket is issued for failure to do something we were required to do. Application: Ifa package ofACETONE was marked ACETONEE instead ofACETONE for the Proper Shipping Name that is a violation ofthe Hazardous Materials Regulations because it is misspelled. The correct Proper Shipping Name is actually ACETONE. If only one package is marked wrong the person offering the package fortransportation and the Carrier that accepts it for transportation each are subject to a Civil Penalty of $25,000. If 10 drums were marked wrong they would be subject to a Civil Penalty of $250,000.00. Criminal Penalty- A Criminal Penalty can be imposed when the Hazardous Materials regulations are violated intentionally. The person Of- fering, Accepting, or Transporting a Hazardous Material knew there were Haz ardous Materials Regulations cov- ering the material being shipped, and either Offered or Accepted the shipment for transportation or transported it in viola- tion ofthose regulations. It was not a mistake as is most often the case in a Civil Penalty but an intentional act to Offer, Accept, or Transport a shipment of Hazardous Materials in violation of Materials Regulations. Application: As a general rule a person who intentionally Offers a package of Hazardous Materials requiring a "POISON" label without the label because they have to have it somewhere quick and the Carrier won't accept "POISON" labeled packages has committed a Criminal violation. They have intentionally failed to perform an act that they knew the regulations required them to perform and could face a Criminal Fine of up to $500,000 and/ or up to Five (5) years imprisonment. Intro-2 (0691) O 1991 GSI Conqtuter Services Inc., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130674 irrassment- Shipments that are not in compliance with the Hazardous Materials Regulations can cause embarrassment to our Industry, Company or Organization, and ourselves. All ofus at one time or another have heard of a shipment ofHazardous Materials that either leaks, explodes, bums, turns into a cloud or does some other neat thing that it's not supposed to do while in the transportation system. Application: Millions of square miles to leak in but, as the result of an accident, a shipment ofTen 55 gallon metal drums of "Poisonous Killer Pesticide", a Division 6.1 Hazardous Material, is leaking from the back of the truck that it is being transported on in the middle of rush hour on the busiest expressway in the city. The truck is not placarded POISON and the leaking drums are not labeled POISON. Under normal conditions, in addition to Emergency Response personnel, the media also shows up. As the emergency is being handled it is discovered that the shipment was not in compliance with the Hazardous Materials Safety Regulations after two Emergency Response personnel and the Channel 89 News Anchor Person have been exposed to and injured by the effects ofthe leaking material. Instant embarrassment to the chemical and pesticide industry, the Shipping Organization or Company that Offered the shipment for transportation, and the Carrier that Accepted and Transported it. The probabilities are also great that personal and profes sional embarrassment will result to the individual or individuals within the Shippers Organization that had the responsibility to label the packages and provide the Placards to the carrier if the vehicle was not already placarded. BOTTOM LINE=SAFETY These are safety regulations. They set forth the minimum acceptable standards of safety. At times the individual parts may seem petty, but generally, when considered in total, the Hazardous Materials Regulations do provide a system that permits the transportation of Hazardous Materials safely. A package of AMMONIUM NITRITE is marked with the Proper Shipping Name of AMMONIUM NITRATE instead ofAMMONIUM NITRITE. At first blush it seems pretty petty. So what an A for an I. They are both vowels. That difference is the difference between a material classed as an "Oxidizer" (AMMONIUM NITRATE) which may be transported in the transportation system ifin compliance with the Hazardous Materials Regulations and a material that is very unstable and has explosive properties (AMMONIUM NITRITE) which is generallyprohibited in the transportation system. Seemingly small and petty things can and do impact on safety! Intro-3 (0691) O 1991 GS1 Confute! Scrvioa Inc., Bmaon, MO 65616 RepriWed with pcuuiition. AD rights reserved ABDOO130675 THE A. B. C's OF REGULATORY ORGANIZATION A. Reasons for Knowing How Regulations Are Organized- Imagine a telephone book that was not sorted alphabetically. It would be hard to look up a number, the information needed, because there was no organization to it. The problem would be the same if the person seeking the information did not know how the telephone book was organized. Most of us, one way or another have learned that a telephone book is organized alphabetically by name and have no problem using it to get the information we need. 49 CFR contains the minimum Federal safety standards applicable to the transportation of Hazardous Materials. To be in compliance with them we must know how they are organized so that the information needed can be found and used effectively. B. What is 49 CFR and the Code ofFederal Regulations (CFR)- The vast majority ofregulations published by the Federal Government are published in the Code of Federal Regulations which is commonly abbreviated or referred to as CFR. The Code of Federal Regulations (CFR) is broken into numbered Titles with each Government Agency given their own numbered Title. Visualize a set of encyclopedias consisting of many Volumes. Each volume is numbered and contains specific information. The Code of Federal Regulations (CFR) is the "encyclopedia of Government Regulations'* consisting of many Titles (Volumes) each of which is numbered and contains the regulations pertaining to a specific agency and subject. The Title of the CFR containing the U.S. Department of Transportations Hazardous Materials Regulations is Title 49 (49 CFR). This is commonly referred to as 49 CFR. The Hazardous Waste and Substance regulations of the U.S. Environmental Protection Agency (EPA) are contained in Title 40 of the CFR (40 CFR). C. The Relationship Between the Title, Chapter, Sub Chapter, and Part- Titles are divided into Sub Titles, Chapters, Sub Chapters, Parts, Sub Parts, Sections, Paragraphs, Sub Paragraphs etc. The U.S. DOT'S Hazardous Materials regulations covered in this text are all contained in Sub Chapter C of Chapter I of Sub Title B of Title 49 CFR which is entitled "Hazardous Materials Regulations". Sub Chapter C is divided into Parts. Parts run numerically from the front to rear of49 CFR starting with Part 171 and ending with Part 179. The relationship between a Title, Chapter, Sub Chapter, and Part are illustrated in Figure 2. It is helpful to remember that all the U. S. Dot Hazardous Materials Regulations are contained within Sub Chapter C. From time to time the Hazardous Materials Regulations (Parts 171-180 of49 CFR) will contain language referring to "this Sub Chapter". The Sub Chapter being referred to is Sub Chapter C. Title 49-TRANSPORTATION SUB TITLE B- Other Regulations Petaining To Transportation Chapter I- Research and Special Programs Administration SubChapter C- Hazardous Materials Regulations Parts- 171-180 FIGURE 2 D. Keys to Everyday Use- Sections and Paragraphs Parts are broken down into Sections which run, relatively speaking, numerically within the Part, starting with "1". For day to day use the specific information that will be used will be found withinthe Sections and Paragraphs of the various Parts of 49 CFR.' The reference to 172.101 in Figure 3 refers to the 101st Section within Part 172. The Section starts with the first series of numbers to the right of the period after the Part. A Section reference must include the Part because each Part could have a Section " P'* in it. A reference to 171.1 refers to the first Section within Part 171. A reference to 177.1 refers to the first Section within Part 177. The Part and the Section together however form a unique reference i.e. 171.1, 172.1, or 173.1 etc. Intro-4 (0691) O 1991 GS1 Computer Services Inc., Branson, MO 65616 Reprinted with pennaeioo. All rights reserved. ABDOO130676 Sections are divided into Paragraphs, Sub Paragraphs etc. The first non capital (lower case) letter in parens to the right of the Section is the Paragraph. The first Arabic (American) number in parens to the right of the Paragraph is the Sub Paragraph. The (c) in Figure 3 illustrates a Paragraph reference and the (10) a Sub Paragraph reference. Part Section (Paragraph) (Sub Paragraph) FIGURE 3 It should be noted that Sub Paragraphs are further broken down into Sub Sub Paragraphs which will be the first lower case Roman Numeral in parens after the Sub Paragraph and Sub Sub Sub Paragraphs which are indicated by a Capital letter in parens. The reference 172.101(c)(10)(i)(A) refers to Sub Sub Sub Paragraph (A) of Sub Sub Paragraph (i) of Sub Paragraph (10) of Paragraph (c) of Section 172.101. 172.101(c) Level 1 Paragraph 172.101(c)(10) Level 2 Sub Paragraph 172.101 (c)( 10)(i) Level 3 Sub Sub Paragraph 172.101 (c)( 10)(i)(A) Level 4 Sub Sub Sub Paragraph Figure 4 E. Sub Parts- Although not used for day to day research it should be noted that the Parts are divided into Subparts containing Sections. Subparts are lettered with a Capital (UPPER CASE) letter alphabetically within the Part. Subpart A, Subpart B, etc. Sections are contained within these Subparts and are numbered consecutively throughout the Part without regard to the Subpart they areJn and do not start at .1 with each new Subpart. Sub Part C of Part 172 entitled Shipping Papers contains Sections 172.200 through 172.205. Sub Part D the next Subpart contains the Marking Requirements. It starts with Section 172.300. The only reason we need to know about Sub Parts is because on occasion 49 CFR will refer to a Sub Part. A reference to Sub Part F of Part 172 is a reference to Sections 172.500-172.560 containing the regulations pertaining to Placarding. < Intro-5 (0691) O 1991 GSI Conjwter Service* Inc., Branson, MO 65616 Reprinted with penniuioa. AU rights reserved ABDOO130677 RESERVED- Intentionally left blank. Next page is 1. Intro-6 (0691) 1991GSI Confute* Semces tnc^ Borneo. MO 656ld Reprinted witb perausstoo. All rights reserved. ABDOO130678 THE A. B. C's OF USING THE S 172.101 TABLE (HAZARDOUS MATERIALS TABLE) A. Kev to Compliance- Proper use of the 172.101 Table The Hazardous Materials Table (172.101 Table) in 172.101 of 49 CFR is set up similar to a "Telephone Book". It lists information alphabetically by Column and requires the use ofthe right name to get the right information. The Column Titles at the top of each Column describes the information contained in the Column. The Columns of the 172.101 Table (Hazardous Materials Table) are organized Alphanumerically (1) through (10B). The contents of each Column will be discussed below as well as its relationship to the other functions necessary to achieve safety and compliance (172.101(b)-172.101(k)). B. Column fll- Symbols: + Fixes the Proper Shipping Name, Hazard Class, and Packing Group without regard to whether or not the material actually meets the definition of that Hazard Class or Packing Group or any other Hazard Class or Packing Group (172.101(b)(1)). A Means that the material covered by the entry is regulated as a Hazardous Material only when being transported by air except if the material is regulated as a Hazardous Substance or Hazardous Waste, in which case it is regulated by all modes including air (172.101(b)(2)). D Identifies Proper Shipping Names which may be used for domestic transportation but will, in most cases, not be appropriate for transportation under International Dangerous Goods regulations such as ICAO or the IMDG Code. An alternate Proper Shipping Name may be selected(172.101(b)(3)). The D in the Aldrin, liquid entry in Figure 2A illustrates the use of this symbol. I Identifies Proper Shipping Names which are appropriate for international transportation under International Dangerous Goods regulations such as ICAO or the IMDG Code. An alternate Proper Shipping Name may be used if only domestic transportation is involved (172.101(b)(4)). As a practical matter when shipping under the authority of International Regulations such as ICAO or the IMDG Code, most shipments of Hazardous Materials will be described using Proper Shipping Names selected from either ICAO (171.11) or the IMDG Code (171.12(b)). W Means that the material covered by the entry is regulated as a Hazardous Material only when being transported by water except if the material is regulated as a Hazardous Substance or Hazardous Waste, in which case it is regulated by all modes including water (172.101(b)(5)). C. Column (21 - Proper Shipping Name: This Column contains the Proper Shipping Name which is required to be marked on each package or overpack, entered on the Shipping Paper, and is the KEY TO COMPLIANCE and SAFETY. It is the starting point for the handling or processing of all Hazardous Materials or Dangerous Goods shipments. It establishes the "Row" or "Entry" in the Hazardous Material Table which contains the information needed to process the shipment such as the Class or Division, Identification Number, Packaging Authorizations, Labels, etc. GSI CR: B. Packaging Authorization, 27; A. Marking, 35; A. Labeling, 39; A. Shipping Papers, 45 The Proper Shipping Name must be the MOST appropriate entry appearing in Column (2) in Roman Type that describes the Hazardous Material being shipped (172.101(c)). Reference to Figure 2A shows that Acetone would be a Proper Shipping Name for the chemical "Acetone" being shipped in its commercially pure form. Italics are not part of the Proper Shipping Name. In the Aldrin, liquid entry, illustrated in Figure 2A, the Proper Shipping Name is Aldrin. There is a Proper Shipping Name for EVERY Hazardous Material contained in Column (2) of the Hazardous Materials Table. Ethvlcvclohexane is not specifically listed by its Technical or Chemical name in the Hazardous Materials Table. In its commercially pure form it is regulated as a Hazardous Material because it meets the definition of a Class 3. The most appropriate generic or n.o.s. Proper Shipping Name listed in the Hazardous Materials Table must be selected. In the case of Ethvlcvclohexane the Proper Shipping Name would most likely be Flammable liquids, n.o.s.. GSI CR: A-B. Classification, 7; A. Proper Shipping Name, 11; A. Technical Name Rule, 15 1 (0691) 01991 GSI Computer Services Inc., Brinson, MO $5616 Reprinted witb penmseioo. AH rights reserved. ABDOO130679 Impact of Prefixes and Numbers on the Alphabetical Order of the Proper Shipping Names As a general rule the Hazardous Material Table is arranged in alphabetical order without regard to the following: 1. Numbers. To find 1,1,1-TrichIoroethane look under Trichloroethane, not 1,1,1-. in the Hazardous Materials Table. 2. The following Single Letters or Descriptions: Single Letters Descriptions a- b- alpha beta m- N- meta omega n- O- sec tert 0- PFigure 2A illustrates the n-Propyl nitrate entry in the Hazardous Material Table. The user would have to look under P entries for Propyl nitrate and ignore the prefix n-. Neither n-Propyl nitrate nor Propyl nitrate is listed in the n entries of the Hazardous Material Table.. Symbol (1) Hazardous Material Table - 172.101 Table Hazardous materials descriptions and proper shipping names (2) Hazard class or Division (3) Identification Numbers (4) Packing group (5) Acetone D Aldrin, liquid n-Propyl nitrate 3 UNI 090 n 6.1 NA2762 n 3 UN1865 n FIGURE 2A D. Column (31 - Class or Division: This Column contains the Class or Division assigned to the Proper Shipping Name covered by that entry or the word "Forbidden" (172.101(d)). In Figure 2A Column (3) shows the Hazard Classes or Division for the entry Acetone as 3. The Class or Division must be entered on the Shipping Paper as part of the Basic Description (172.202(a)). If the word "Forbidden" appears in Column (3) the material covered by the entry may not be offered for transportation without special processing or approvals (172.101(d)(l)-(2)). A complete list of the different Classes, Divisions, and Definition Sections is contained in 173.2 and the GSI 49 CFR Class/Division Table on page 10. GSI CR: Classification, 7; GSI Class/Division Table, 10; C. Shipping Papers, 46; E. Placarding, 56 E. Column (41 - Identification Number: This Column contains the Identification Number assigned to the Proper Shipping Name (172.101(e)). As a general rule the Identification Number must be marked on each package or overpack and entered on the Shipping Paper. The prefix NA as illustrated in the Aldrin, liquid entry in Figure 2A indicates Proper Shipping Names that are not recognized for international transportation, except, in certain cases, for shipments to and from Canada. The prefix UN, as illustrated in both the Acetone and n-Propyl nitrate entries indicates that the Proper Shipping Name covered by the entry would be appropriate for both international and domestic transportation. As a practical matter when shipping under the authority of International Regulations such as ICAO or the IMDG Code, most shipments of Hazardous Materials will be described using the prefix and numbers associated with the Proper Shipping Name selected from either ICAO (171.11) or the IMDG Code (171.12(b)) as appropriate. The appropriate Prefix shown as part of the Identification Number in Column (4) must be marked on each Non Bulk packaging as pait of the Identification Number marking required by 172.301(a) and entered on the Shipping Paper as part of the Identification Number required in the Basic Description (172.202(a)). GSI CR: C. Identification Number, Marking, 35; D. Shipping Papers, 46 2 (0691) O 1991 GSI Computer Service* toe., Branco, MO 65616 Reprinted with p^mminn All rights reserved. ABDOO130680 F. Column (51 - Packing Group: Column (5) contains the Packing Group, if any, assigned to the Hazardous Material covered by the entry. The Packing Group will be an upper case Roman Numeral I, II, or III depending on the degree of hazard i.e. I Most Hazardous (Most Regulated), II Moderately Hazardous (Moderately Regulated), and III Least Hazardous (Least Regulated) (172.101(f)). Column (5) of Figure 2A shows that the Packing Group for all the entries illustrated is II. The Packing Group must be entered on the Shipping Paper as part of the Basic Description (172.202(a)). GSI CR: Packing Group, 6; B. Classification, 7; E. Shipping Papers, 46 G. Column (1 - Labels: This Column contains the Primary and Subsidiary Hazard (Risk) labels that must be affixed to each package or overpack. Column (2) for the entries in Figure 3A indicates that the FLAMMABLE LIQUID label must be affixed to each package or overpack containing Acetone and that both CORROSIVE and FLAMMABLE LIQUID labels must be affixed to each Dlchlorobutene package or overpack. Generally ifmore than one (1) label is listed, the first label listed represents the Primary Hazard and the second and subsequent label(s) represent the Subsidiary Hazard(s) (172.101(g)). It should be stressed that 172.402 mav require that labels other than those shown in Column (6) be affixed to the package or oveipack IN ADDITION to those contained in Column (6) (172.101(g)). GSI CR: A. Labeling, 39 H. Column (Ti - Special Provisions: Column (7) contains the codes for "Special Provisions" IF ANY, which could apply to the Hazardous Materials covered by the entry (172.101(h)). The specifics of each Special Provision is contained in 172.102. The Codes generally apply as follows: Alpha numeric Codes: A- Air transportation only. B- Bulk Packagings, except, in most H- Highway only. cases IM Portable Tanks. N- Non Bulk Packaging only. R- Rail only. T- IM Portable Tanks only. W- Water transportation only. Numerical Codes: Apply to all modes, bulk and non bulk packaging if applicable. Hazardous Material Table - 172.101 Table Hazardous materials Proper Shipping Names (2) Label(s) Required (6) Special Provis. (7) Non Bulk Bulk Pass. Cargo Vessel Other Excep- Pack- Pack- Aircraft Aircraft Stow- Provisions tions agings agings Railcar Only age (8A) (8B) (8C) (9A) (9B) (10A) (10B) Acetone FLAMMABLE LIQUID Calcium hydride DANGEROUS WHENWET Dichlorobutene CORROSIVE, FLAMMABLE LIQUID T8 150 202 A19 None 211 N40 None 201 242 5L 60L 242 Forbidden 15 kg 243 0.5L 2.5L B E C 12,21,25 40,48, M4 FIGURE 3A Knowledge ofCode meanings and applicability can eliminate a lot offlippingback and forth between 172.101 and 172.102. Reference to Column (7) of the Calcium hydride entry in 172.101 or Figure 3A indicates 2 Codes that could apply. If, however, we are shipping a bulk packaging of Calcium hydride, none applies. The Codes with the Prefix N apply only to Non Bulk Transportation and those with the prefix A apply only to transportation by air. I. Column 181 - Packaging Authorizations: Column (8) contains the Sections within Part 173 of 49 CFR authorizing the packaging to be used (172.101(i)). It is divided into 3 Columns as follows: Column (8A)- Contains the Section within Part 173 containing exceptions to some ofthe requirements of the regulations. The word "None", as illustrated in the Calcium hydride and Dichlorobutene entries in Figure 3A, in this Column means that there are no exceptions except as may be authorized under the 3 (0691) O 1991 GSI Coo^uter Soviets Inc., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130681 Special Provisions in Column (7) ofthe 172.101 Table. The entry 150 in Column (8A) for the Acetone entry in the 172.101 Table orofFigure 3A indicates that exceptions authorized forAcetone will be found in Section 173.150. It should be pointed out that there may be exceptions authorized elsewhere such as in 173.4. Column (8B)- Contains the Section within Part 173 containing the non bulk packagings authorized to be used. The entry 202 in Column (8B) for the Acetone entry in the 172.101 Table or Figure 3A indicates that the non bulk packaging authorized for Acetone will be found in Section 173.202. Column (8Q- Contains the Section within Part 173 containing bulk packagings authorized to be used. The entry 242 in Column (8C) for the Acetone entry in the 172.101 Table or Figure 3A indicates that the bulk packaging authorized for Acetone will be found in Section 173.242. J. Column 191 - Quantity Limitations: Column (9) is divided into two columns containing the maximum quantity that may be offered per package for transportation aboard "Passenger carrying aircraft or rail car" (Column (9A)) or Cargo Aircraft (Column (9B)). The entry 5 L in Column (9A) for the Acetone entry in Hazardous Materials Table or Figure 3A indicates that up to 5 L of Acetone may be offered PER PACKAGE for transportation aboard ` `Passenger carrying aircraft or rail car. ' ' The entry 60 L in Column (9B) for the Acetone entry in the Hazardous Materials Table or Figure 3A indicates that up to 60 L of Acetone may be offered PER PACKAGE for transportation aboard Cargo Aircraft. Except where otherwise indicated the quantities indicated are "net** not "gross". The word "Forbidden," as illustrated by the Calcium hydride entry in Figure 3A in Column (9A), means that the Hazardous Material covered by the entry may not be offered for transportation aboard Passenger carrying aircraft or railcars. The word "Forbidden" appearing in Column (9B) indicates that the Hazardous Material may not be offered for transportation aboard Passenger carrying aircraft or railcars or Cargo Aircraft (172.101(j)). The majority of Hazardous Materials transported by air are transported under the authority of ICAO and the quantity per package and packaging will generally be controlled by ICAO. GSI CR: A. Packaging, 27; E. Cargo Aircraft Only Label, 42 K. Column (KB - Vessel Stowage Requirements: Column (10) is divided into two columns. The stowage locations aboard cargo and passenger vessels are contained in Column (10A) by a lettered code. The codes are defined in 172.101(k)(l)-(5). Other stowage requirements applicable to a particular Hazard ous Material are indicated by codes in Column (10B). These Codes are defined in 176.84. The entry "B" in Column (10A) for the Acetone entry in either the Hazardous Materials Table or Figure 3A indicates that shipments of Acetone may be stowed "on deck" and "below deck" on a cargo vessel but must be stowed "on deck" on passenger vessels (172.101(k)). 4 (0691) 1991 GSI Con^user Services lac., Bmaoa, MO 65616 Reprinted with permission. All rights reserved. ABDOO130682 CLASSIFICATION & PACKING GROUP gasification Terminology Class or Classification- Term used in International Regulations such as ICAO, IATA, IMDG, and the Canadian TDG Regulations for what 49 CFR calls the Hazard Class. (See " Hazard Class" below.) Commercially Pure- As used in this text the term "Commercially" or "Technically" Pure means a material as it is commonly manufactured without the addition of any outside ingredients which would cause it to become a mixture or solution. It includes those impurities which are a natural result of the manufacturing process and includes "Reagent" as well as "Technical" Grade chemicals that are not mixtures. Hazard Class- The category or type of Hazard assigned to a material. There are nine (9) Classes numbered 1 through 9. Each has its own Definition Section within Part 173. Generally the first paragraph within the Definition Section will contain the "Class Definition". Figure 7A on page 7 illustrates paragraph 173.1201'a'l which contains the Definition for "Class 3 Flammable Liquids" in Sub Paragraph 173.120(a)(1). A complete list ofthe Classes and Divisions, definition references, and a summary ofthe hazards involved with each will be found in the "GSI 49 CFR CLASS/DIVISION REFERENCE TABLE" on page 10. Section 173.2 of 49 CFR contains a list of the Classes, Divisions, and their 49 CFR Definition Section. Symbol (1) Hazardous Materials Table - 172.101 Table Hazardous materials descriptions and proper shipping names (2) Hazard class or Division (3) Identification Numbers (4) Packing group (5) Acetone D Aldrin, liquid n-Propyl nitrate 3 UN1090 II 6.1 NA2762 n 3 UN1865 n FIGURE 5A Although some materials may meet the definition of more than one category or class, each Hazardous Material will be assigned to only one Hazard Class in either Column (3) of the Hazardous Material Table or through the hazard precedence procedure contained in Section 173.2a for most mixtures and materials not specifically listed in the Hazardous Material Table (172.101(d) & 173.2a). GSI CR: A.-B. Classification, 7; C. Shipping Paper, 46; E. Placarding Selection, 56 Hazardous Material- A material, substance, or article which is capable of posing an unreasonable risk to health, property, and safety while in the transportation system and has been so designated by the Secretary of the Department of Transportation (171.8). The Secretary designates these substances and materials as "Hazardous Materials" in one of two (2) ways: 1. Listing them by their chemical (Technical) name in the Hazardous Material Table (172.101 Table). Commercially pure Acetone is regulated as a Hazardous Material because it is specifically listed in the Hazardous Material Table (172.101 Table). The Acetone entry in Column (2) of Figure 5A illustrates this method of Classification. OR 2. By setting up criteria for "Hazard Classes" or "ORM Categories" which automatically causes all materials meeting the criteria to be regulated as "Hazardous Materials". Ethvlcvclohexane. a liquid having a Flash point of 35C (95F), is regulated as a "Hazardous Material" because it meets the definition of a Class 3 Flammable liquid. A material meets the definition of a Class 3 under 49 CFR if its Flash point is not more than 60.5C (141F) (173.120(a)(1)). Division- Some Classes such as 1,2,4,5, and 6 are broken down into Divisions which is indicated by a decimal number after the Class Number. Reference to the "GSI 49 CFR CLASS/DIVISION REFERENCE 5 (0691) O 1991 GSI Congwto Soviets lac., Brasoo, MO 6S6I6 Reprinted with AD rights reserved. ABDOO130683 TABLE" on page 10 or 173.2 indicates that Class 6 has two Divisions. The 6.1 in the Aldrin entry in Column (3) of Figure 6A below is a Division. The number to the left ofthe "." is the "Class" and the Number to the right ofthe ".** is the "Division'*. Aldrin is in 6.1 which is Division "1" ofClass "6". Mixture- A material composed of more than one chemical compound or element (49 CFR 171.8). A mixture may be either a liquid, solid, or gas. Some materials such as Carbon dioxide and oxygen mixture are specifically identified as mixtures in the Hazardous Material Table. Others such as Paint or Ink, which are a combination of other chemical compounds or materials, are examples of materials which, although a mixture, are not specifically identified as such in the Hazardous Material Table. (See "Solution" below.) Packing Group- The degree of hazard. The Class or Division represents the type of Hazard associated with the Hazardous Material, 6.1, 8, etc. The "Packing Group" represents the degree of that type of Hazard within the Transportation System. Where applicable the Packing Group will be an Upper Case Roman Numeral I, II, or III (171.8). The lower the Packing Group Number the greater the degree of risk and the more it will be regulated. Among other things, the Packing Group dictates the entries in Columns 6-10(B) ofthe HMT-172.101 to be used, governs some of UN Performance tests for packaging, is a code marked on UN Specification Packaging, and is a required entry on the Shipping Paper. Packing Group I- Greatest degree of Risk (Most Regulated) Packing Group II- Moderate degree of Risk (Moderately Regulated) Packing Group III- Least degree of Risk (Least Regulated but Regulated) For materials specifically identified by their Technical Name in the 172.101 Table the Packing Group, if applicable, will be found in Column (5) of the entry. In addition, certain Classes and Divisions such as 3, 4.1, 4.2, 4.3, 5.1, 6.1 and 8 have Packing Group criteria which must be considered in Classifying Hazardous Material Table - 172.101 Table Sym- Hazardous materials descriptions and bol proper shipping names (1) (2) Hazard class or Division (3) Identification Numbers (4) Packing group (5) Acetone Ink, printer'sflammable D Aldrin, liquid 3 UNI 090 n 3 UN1210 n 6.1 NA2762 u FIGURE 6A Hazardous Materials not specifically identified in the 172.101 Table by their Chemical (Technical Name) (172.101(f)). The "Packing Group Criteria" will usually be found in a Section which closely follows the Definition Section. Figure 7A illustrates this point for "Class 3 Flammable Liquids". The Packing Group Criteria is found in Section 173.121 which comes immediately after the Definition Section 173.120. GSI CR: A.-B. Classification, 7; B. Packaging, 27; E. Shipping Paper, 46 Primary Hazard- See "Hazard Class" above. Solution- A homogeneous liquid mixture of two (2) or more chemical compounds that will not undergo any segregation (separation) under conditions normally incident to transportation (49 CFR 171.8). It can be generally said that a "solution" is a "specialized type ofmixture' ' because a solution must first be a mixture. It then becomes a solution IF it is a liquid AND will not separate under conditions normally incident to transportation. Some materials, such as Ammonia solutions, are specifically identified in the 172.101 Table as solutions and others such as Paint or Ink etc., are examples of mixtures which could be a "solution". (See "Mixture" above.) Subsidiary Hazard (Riskl- The Subsidiary Hazard (Risk) means a hazard of the material other than its Hazard Class (Primary Hazard). It applies to materials meeting the definition of more than one hazard 6 (0691) O 1991 GSI Computer Services Inc., Bransoo, MO 65616 Reprinted witb pcnmssion. All rights reserved. ABDOO130684 class and is a hazard of the material other than its Primary Hazard as shown in either Column (3) of the Hazardous Materials Table or as determined using the Precedence of Hazard Table in 173.2a(b) when appropriate. It can impact areas such as the selection of the Proper Shipping Name, labeling, and Shipping Paper entries. (See "Hazard Class" on page 5.) GSI CR: B. NOS Technical Name Rule, 15; B. Subsidiary Risk Labeling, 40 Technical Name- Recognized chemical name currently used in technical and scientific texts, journals, and handbooks (171.8). Technically Pure- See "Commercially Pure". It All Starts With The Hazard Class For a material to be regulated as a Hazardous Material under 49 CFR it must meet the definition of one of the Classes or Divisions contained in Part 173 of 49 CFR. The First Step is to determine IF the material being shipped is regulated as a Hazardous Material because it meets the criteria of one or more of the Classes or Divisions contained in Part 173 of 49 CFR. If the material being shipped does not meet the criteria of one or more of them it is not regulated as a Hazardous Material. Ifthe material being shipped meets the criteria of one or more of the Hazard Classes or Divisions contained in Part 173 it is regulated as a Hazardous Material. Ifthere is a Packing Group Criteria for the Class or Division ofthe material being classified, it too must be determined. GSI CR: GSI 49 CFR Class/Division Cross Reference Table, 10; A.-C. Proper Shipping Name, 11 173.120 Class 3-Definitions (a) Flammable Liquids. (1) For the purposes of this subchaper, a "flammable liquid" (Class 3) . means any liquid having a flash point not more than 60.5C (141F). 173.121 Packing Group Criteria Packing Group Flash Point (Closed Cup) Initial Boiling Point I II <23C (73F) III =>23C (73F) but =<35C (95F) >35C (95F) >35C (95F) =<60.5C (141F) FIGURE 7A Illustration: Reference to Figure 7A indicates that an "Ink" having a Flash Point of 20C (68F) and an Initial Boiling Point of over 35C (95F) would be regulated as a Class 3 with a Packing Group of II. On the other hand, an "Ink" not meeting the definition of any of the Classes or Divi sions in Part 173 of 49 CFR would not be regulated as a Hazardous Material even though "Ink" is listed in the Hazardous Materials Table. THE A. B. C'sOF CLASSIFICATION A. Commercially Pure Materials Specifically Identified_Bv Their Technical Name- As a GENERAL RULE commercially pure materials specifically identified in Column (2) of the 172.101 Table with a Proper Shipping Name that is their specific chemical or technical name will be regulated under the Class specified in Column (3) and the Packing Group shown in Column (5) for the entry (172.101(c)). Reference to Columns (2), (3), and (5) in Figure 6A for "commercially pure" Acetone indicates its Proper Shipping Name is Acetone, it is regulated as a Class 3, and has a Packing Group of II. GSI CR: A. Proper Shipping Name, 11; B. Specifically Listed Material Rule, 12 7 (0691) O 1991 GSI Conjurer Services lac.. Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130685 B. Mixtures^ Solutions. _ and Materials NOT SPECIFICALLY Identified By Their Technical NamesMixtures and materials NOT specifically identified in Column (2) of the Hazardous Materials Table by a Proper Shipping Name that is their specific chemical or technical name must be classified by: 1. Comparing their characteristics against the criteria listed in Part 173 of49 CFR to determine the Class or Classes under which the material is regulated IF ANY. A complete list of the 49 CFR Classes and Divisions, definition references, and a summary ofthe hazards involved will be found in the "GSI49 CFR CLASS/DIVISION REFERENCE TABLE" on page 10. and, for those Classes or Divisions having a Packing Group Criteria 2. Comparing their characteristics against the Packing Group Criteria to determine the Packing Group. GSI CR: Packing Group, 6; Technical Name Rule, 15 Symbol a) Hazardous Material Table-172.101 Table Hazardous materials descriptions and proper shipping names Hazard Identifi- Pack Label(s) Required class or cation ing (If not excepted) Division Numbers group (2) (3) (4) (5) (6) Acetone Benzene Flammable liquids, n.o.s. Flammable liquids, corrosive, n.o.s. 3 UN1090 n 3 UN1114 n 3 UN1993 n 3 UN2924 i FIGURE 8A FLAMMABLE LIQUID FLAMMABLE LIQUID FLAMMABLE LIQUID FLAMMABLE LIQUID CORROSIVE a. Technically Pure Chemicals - Technically pure "Ethylcyclohexane" has a Flash Point of 35C (95F), an Initial Boiling Point over 35C (95F), and is not listed by its chemical name in Column (2) ofthe Hazardous Materials Table. Information from Sections 173.120 and 173.121 of Part 173 is contained in Figure 7A. A comparison ofthe characteristics of "Ethylcyclohexane" against the definition paragraph indicates that "Ethylcyclohexane" is regulated as a Class 3 because its Flash Point is less than 60.5C (141F). Further a comparison ofthe Flash Point and Initial Boiling Point of "Ethylcyclohexane" against the Packing Group Criteria contained in 173.121 indicates that "Ethylcyclohexane" would be in Packing Group III because the Flash Point is above 23C (73F) and the Initial Boiling Point is above 35C (95F). The Proper Shipping Name, (Technical Name in parentheses), Class, UN Number, and Packing Group would be: Flammable liquids, n.o.s. (Ethylcyclohexane), 3, UN 1993, PG III b. Single Class Mixtures- A mixture of "Acetone" and "Benzene" having a Flash Point of 24.4C (76F) and an Initial Boiling Point of more than 35C (95F) which is not specifically identified in Column (2) of the Hazardous Materials Table by its technical name would be classified as follows. Reference to the 172.101 Table or Figure 8A indicates that although both "Acetone" and "Benzene" are listed separately their mixture is not. It's like combining Rum and Coke. When they are put together the resulting mixture has a different "name", "Rum and Coke". If a "Rum and Coke" was desired a person would not order "Coke". If a person wanted a "Coke" and ordered "Rum and Coke" they sure would be surprised at the result. A comparison of the characteristics of the mixture against the Class 3 Definition and Packing Group Criteria illustrated in Figure 7A indicates that the mixture of "Acetone" and "Benzene" would be Classed as a 3 and have a Packing Group of III because the Initial Boiling Point is above 35C (95F) with 8 (0691) O 1991 GSI Computer Services Inc., Branson, MO 65416 Reprinted with penmsikxL All rights resaved. ABDOO130686 a Flash Point of 24.4C (76F). The Proper Shipping Name, (Technical Name in parentheses), Class, UN Number, and Packing Group would be: Flammable liquids, n.o.s. ( Acetone/Benzene ), 3, UN 1993, PG III c. Multiple Class Materials or Mixtures- If a material or a mixture that is not specifically identified in Column (2) ofthe Hazardous Materials Table by its Technical name or a mixture of materials meets the definition of more than one (1) Class, the (Primary) Hazard Class must be determined in accordance with the precedence indicated in Section 173.2a of 49 CFR. For Hazardous Materials classed as 3, 4.1, 4.2, 4.3, 5.1, 6.1, or 8 the precedence is generally determined by Precedence of Hazard Table in 173.2a(b) of 49 CFR, a portion of which is illustrated in Figure 9A below. The Primary Hazard Class will be the Class or Division appearing at the intersection of the row and column where the two Classes or Divisions, including their physical form and toxicity criteria, where appropriate, meet. The Subsidiary Risk (Hazard) will be the Class or Division that is not the (Primary) Hazard Class. If the Packing Groups for the Primary Hazard and Subsidiary Hazard are different the most stringent Packing Group must be used. Precedence Of Hazard Table Illustration (173.2afl>Yl 6.1,1 6.1,1 6.1,11 6.1,111 8^ !_8] 8,11 dermal oral liquid liquid 3 13 [^II] 3 3 3 33 33 3 3 III 6.1 6.1 6.1 3 8 (3) Impossible combination ----- Used to indicate other entries omitted from illustration [1i 3 ] 8 FIGURE 9A solid (3) (3) o 8,III liquid 3 3 3 Application: Using the Precedence of Hazard Table in 173.2a or Figure 9A it can be determined that a mixture of "Methanol" and "Potassium hydroxide" meeting the definition of both a Class 3, Packing Group II and a Class 8 Packing Group II would have a Hazard Class of 3, a Packing Group of II, and a Subsidiary Risk (Hazard) of 8. The [1 ] in Figure 9A illustrates that the Class or Division Number which appears at the point in the Table where the two (2) Classes and Packing Groups of the mixture intersect is a 3. Class 3 receives the Precedence and becomes the Primary Hazard. The Subsidiary Risk of the mixture will be 8 as indicated by the in Figure 9A. The Packing Group of the mixture will be II because it is the common Packing Group for both of the ingredients of the mixture. If the constituents had different Packing Groups the Packing Group assigned to the mixture would be the one that is the most stringent Packing Group. The Proper Shipping Name, (Technical Name In Parentheses), Class, UN Number, Packing Group, and Subsidiary Risk for the mixture would be: Flammable liquids, corrosive, n.o.s. (contains Methanol/Potassium hydroxide) 3, UN 2924, PG H, 8 9 (0691) 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with penmssion. All right* reserved. ABDOO130687 GSI49 CFR CLASS/DIVISION REFERENCE TABLE 49 CFR Class or Division Name of Class or Division Definition Reference Example(s) Brief*1 Description ofType of Hazard 1.1 Explosives*2 173.50(b)(1) Black powder Mass explosion. 1.2 Explosives*2 173.50(b)(2) Rocket Motors Projection hazard. 1.3 Explosives*2 173.50(b)(3) Fireworks, Type C Fire w/minor blast or projection. 1.4 Explosives*2 173.50(b)(4) Squibs Devices w/minor explosion hazard. 1.5 Explosives*2 173.50(b)(5) Water gels Insensitive but mass explosion. 1.6 Explosives*2 173.50(b)(6) Insensitive article-no mass explosion 2.1 Flammable Gas 173.115(a) Propane Flammable Gas. 2.2 Non Flammable, Contents under pressure 280 kPa compressed, (41 psia) at 20C (68F) & not gas*3 173.115(b) Oxygen, compressed a Division 2.1 or 2.3. 2.3 Poisonous Gas 173.115(c) Oxygen diflouride Poisonous Gas. 3 Flammable Flash Point equal to Liquid 173.120(a) Acetone, Paint or less than 60.5C (141F). Combustible Liquid 173.120(b) >60.5C (14IF) and <93C (200F) 4.1 Flammable Readily combustible, self reactive; Solid 173.124(a) Safety Matches certain wetted explosives. 4.2 Spontaneously Combustible 173.124(b) Wet cotton Pyrophoric or self heating materials. Ignite or heat when exposed to air. 4.3 Dangerous Reacts w/water to give ofFFlamm. or Toxic When Wet 173.124(c) Calcium Carbide Gas or becomes spontaneously combustible. 5.1 Oxidizer 173.127(a) Potassium bromate Yields Oxygen + Fire potential. 5.2 Organic Ammonium nitrate Thermally unstable, bums Peroxide 173.128(a) fertilizers rapidly, sensitive to impact 6.1 Poisonous 173.132(a) Parathion liquid Toxic to humans. Based on LD50 or LC^ Material i.e. Oral LDW 500mg/kg(liquid) 6.2 Infectious Substances 173.134(a) AIDS virus, Viable microorganisms causing disease in humans/ animals. 7 Radioactive Specific Activity greater Materials 173.403 Uranium-233, than 74k Bq/kg(.002 uCi/g) 8 Corrosive Destroys skin w/expos. =< 4 hrs. Materials 173.136(a) Muriatic Acid or metal corrosion rate >6.25mm a Yr. 9 Miscel laneous 173.140(a) Dry Ice Oxygen deprivation 173.140(b) n-Butyl phthalate No other Class but is Hazardous Substance or Waste. ORM-D 173.144 Consumer commodity declassification exception n Summary as to safety hazard only. Definition Sections and Paragraphs must be consulted for specifics. 49 CFR also has Classification Codes & Compatibility Groups for Explosives (173.52)." Includes non flammable, non poisonous Compressed Gases, Liquefied Gases, Pressurized Cryogenic gases, and Compressed Gases in Solution that do not meet the definition of either 2.1 or 2.3. 10 (0691) O 1991 GSI Computer Service* Inc., Branson, MO 65616 Reprinted with penmuioo. All rights reserved. ABDOO130688 THE PROPER SHIPPING NAME The Proper Shipping Name determines the entry or line in the Hazardous Materials Table that is used to make many other determinations such as Hazard Class, UN/NA Number, Packing Group, Labeling, Packaging Authorizations, Passenger and Cargo Quantities, and Vessel Stowage Requirements. It is the key to regulatory compliance and safety and is a required mark on the package and entry on the shipping documentation. Get the wrong Proper Shipping Name and there is virtually no way the shipment can be considered either safe or in compliance. GSICR: B. Packaging, 27; A. Marking, 35; A. Labeling, 39; A. Shipping Papers, 45 THE A. B. C's OF PROPER SHIPPING NAME DETERMINATION A. General Rule- The Most Specific Column (2) entry in Roman Type- The Proper Shipping Name is obtained from Column (2) ofthe Hazardous Materials Table. The name in Column (2) of the Hazardous Materials Table in Roman Type that MOST appropriately (Specifically) describes the Hazardous Materials being shipped MUST be used (172.101(c)(12)). In Figure 11A all the entries in Column (2) except the Dynamite, see entry could be Proper Shipping Names because they are in Roman type. The Dynamite, see entry could not be a Proper Shipping Name because it is not in Roman type. In determining the "most appropriate" Proper Shipping Name from Column (2) the most specific information available, chemical name, product use, etc., should be used in the following order 1. Chemical Name- Ifa material OR mixture is specifically identified by its Chemical (Technical) Name in Column (2) of the Hazardous Materials Table the most appropriate Proper Shipping Name will generally be that entry. This is most applicable when shipping material in its "commercially pure" form such as "Acetone" or normal commercial mixtures of materials listed by their chemical or technical name in the Hazardous Materials Table such as "Calcium hypochlorite mixtures." As illustrated in Column (2) of the Hazardous Materials Table or Figure 11 A, Acetone would be a Proper Shipping Name for "commercially pure "Acetone" and Calcium hypochlorite mixtures, dry would be the Proper Shipping Name for a dry (solid) mixture of "Calcium hypochlorite" classed as a Division 5.1.2 3 Sym bol (1) Hazardous Material Table - 172.101 Table Hazardous materials descriptions and proper shipping names (2) Hazard class or Division (3) Identifi cation Numbers (4) Acetone 3 Alcohols, n.o.s. 3 Calcium hypochlorite mixtures, dry 5.1 D Compounds, cleaning liquid 8 Dynamite, see Explosive, blasting, type A............... Explosive, blasting, type A 1.1D Flammable liquids, n.o.s. 3 FIGURE 11A UNI 090 UN1987 UN2208 NA1760 UN0081 UN1993 2. Generic Chemical or Usage Name- Ifa material or mixture is not identified in the Hazardous Materials Table by its "Chemical Name" the_next most appropriate Proper Shipping Name would be the Generic Chemical or Usage Name listed in Column (2) of the Hazardous Materials Table that best describes the Hazardous Materials being shipped. Examples of these Proper Shipping Names such as Alcohol, n.o.s. and Compounds, cleaning liquid are shown in Figure 11A. 3. General Hazard Class Name- If the Hazardous Material is not more appropriately (specifically) identified in Column (2) ofthe Hazardous Materials Table by any of the above, it must be identified 11 (0691) O 1991 GSI Computer Service* Inc., Branson, MO 6$616 Reprinted with permission. Ail rights reserved. ABDOO130689 by the most appropriate general Hazard Class or other entry in Column (2) such as Flammable liquid, n.o.s.; Corrosive liquid, n.o.s.; Flammable liquid, poisonous, n.o.s.; Environmentally hazardous substances, liquid, n.o.s. etc (172.101(c)(12)(ii)). Application 1. Specific Technical Name in 172.101 Table- Commercially pure "Acetone" has a Flash Point of-17.8C (0F), meets the definition ofa Class 3, Packing Group II, and is specifically listed the 172.101 Table by name. Using Column (2) ofthe Hazardous Materials Table or Figure 12A below the Proper Shipping Name for a shipment of commercially pure "Acetone" is Acetone determined as follows: a. Is the chemical name of the material listed in Column (2) of the Hazardous Materials Table in Bold Type? Yes. The Proper Shipping Name MUST be Acetone. Flammable liquids, n.o.s. would not be an appropriate Proper Shipping Name, even though Acetone is a Class 3, Flammable Liquid, because there is a more specific name listed in Column (2). In most cases when shipping commercially pure materials, the "chemical" or "technical" name listed in Column (2) will be the Proper Shipping Name. Symbol (1) Hazardous Material Table - 172.101 Table Hazardous materials descriptions and proper shipping names (2) Hazard class or Division (3) Identifi cation Numbers (4) Pack ing Group (5) Acetone Environmentally hazardous substances, liquid, n.o.s. Flammable liquids, n.o.s. 3 9 3 D Hazardous waste, solid, n.o.s. AD Other regulated substances, liquid, n.o.s. 9 9 UNI 090 UN3082 UN1993 NA3077 NA3082 II HI I n HI HI HI FIGURE 12A Application 2. Specific Technical Name NOT in 172.101 Table- Commercially pure "Ethylcyclohexane" has a Flash Point of 35C (95F), meets the definition of a Class 3, Packing Group III, and is not specifically listedthe 172.101 Table by name. It is used in "organic synthesis". Using Column(2) of the Hazardous Materials Table or Figure 12A the Proper Shipping Name for this material in its "technically pure" form would be Flammable liquids, n.o.s determined as follows: a. Is the chemical name of the material listed in Column (2) of the Hazardous Materials Table in Bold Type? No. b. Is a Generic or Usage Name listed in the Hazardous Materials Table? No. c. Select the general Hazard Class or other entiy from Column (2) of the Hazardous Materials Table that is most appropriate for the Hazardous Materials being shipped. Flammable liquids, n.o.s. would be the General Hazard Class or N.O.S. entry that most accurately describes "Ethylcyclohexane" because there is not a more specific entry in the 172. lOlTable. GSI CR: B. Technical Name Rule, 15 B. Specifically Listed Materials Mixture Rule- Generally, if A Hazardous Material that is listed in the Hazardous Materials Table by its chemical (technical) name IS MIXED with other materials that are not regulated as Hazardous Materials, the Proper Shipping Name MUST BE the chemical name of the listed material AND the qualifying word "mixture" or "solution" as appropriate (172.101(c)(10)(i)). Application- Commercially pure Acetone is mixed with non regulated materials. The resulting mixture has a Flash Point of20C (68F) and an Initial Boiling Point of more than 37.7C (100F). The Hazard Class, and Packing Group, of the mixture is Class 3, Packing Group, II. Reference to either the 12 (0691) 1991 GSI Computer Soviets lac., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130690 Hazardous Materials Table or Figure 12A indicates that Acetone is listed, has a Hazard Class of 3, and Packing Group of II. The Proper Shipping Name, Hazard Class, UN Number and Packing Group which MUST be used for the mixture is : Acetone Mixture, 3, UN 1090, PG II 1. Exceptions To The Specifically Listed Materials Mixture Rule- The "Specifically Listed Materials Mixture Rule" does not apply IF: a. The Hazard Class, Packing Group, or Subsidiary Hazard of the resulting mixture differs from that of the listed Hazardous Material in it (172.101(c)( 10)(i)(C)). Application- Commercially pure Acetone is mixed with non regulated materials. The resulting mixture has a Flash Point of 29.9C (86F) and an Initial Boiling Point of more than 37.7C (100F). The Hazard Class of the mixture is still 3 but the UN Packing Group changes from II to III. Acetone, the listed Hazardous Material in the mixture, has a Packing Group of II. The Packing Group of the solution is different from that of the listed Hazardous Material in it. The "Specifically Listed Materials Mixture Rule" does not apply and the most appropriate Proper Shipping Name for the mixture must be selected from Column (2) of the Hazardous Materials Table (172.101(c)(10)(ii)). The Proper Shipping Name, Hazard Class, UN Number and UN Packing Group which could be used for the mixture is: Flammable liquids, n.o.s. (Acetone), 3, UN 1993, PG III b. The name in Column (2) of the Hazardous Materials Table specifically indicates it applies only to technically pure substances; the emergency response measures to be taken in the case of an emergency involving the mixture are significantly different from those of the listed Hazardous Materials, the packaging listed in Column (8) of the Hazardous Materials Table for the listed Hazardous Material is inappropriate for the mixture or solution (172.101(c)(10)(i)). GSI CR: "Mixture", "Packing Group", "Solution", 6; A. Technical Name Rule, 15 C. Hazardous Waste Proper Shipping Names- The word Waste will appear as part of the Proper Shipping Name for any Hazardous Waste being transported within the transportation system. If the word Waste does not appear as part of the most appropriate Roman type name for the material selected from Column (2) of the Hazardous Materials Table it must be added preceding the name selected. If technically pure Acetone was being shipped as a Hazardous Waste the Proper Shipping Name would be Waste Acetone (172.101(c)(9)). If the word Waste does appear as part of the Proper Shipping Name selected from Column (2) of the Hazardous Materials Table, as illustrated in the Hazardous waste, solid, n.o.s. entry in Figure 12A, do not add the word Waste or move it from where it appears (172.101(c)(4)). A material that is regulated under 49 CFR only because it is a Hazardous Waste and does not meet the definition of anv other Hazard Class is assigned to Class 9 and MUST be assigned one of the following Proper Shipping Names: Hazardous waste, liquid, n.o.s. Hazardous waste, solid, n.o.s. Waste Environmentally hazardous substances, liquid, n.o.s. Waste Environmentally hazardous substances, solid, n.o.s. D. Proper Shipping Names For Certain Class 9 Hazardous Substances- A material that is regulated under 49 CFR only because it is a Hazardous Substance, and does not meet the definition of any other Hazard Class is assigned to Class 9 and MUST be assigned one of the following Proper Shipping Names: Environmentally hazardous substances, liquid, n.o.s. Environmentally hazardous substances, solid, n.o.s. Other regulated substances, liquid, n.o.s. Other regulated substances, solid, n.o.s. 13 (0691) O 1991 GSI Computer Services Inc., Brusca, MO 6S616 Reprinted with permtaroa All rights reserved. ABDOO130691 . Italics and Other Exceptions: 1. Italics as Additional Information- Column (2) entries in italics are not part of the Proper Shipping Name. Sometimes they are used to provide additional descriptive information as illustrated in the Aldrin, liquid and Aldrin, solid entries in Figure 14A. The words liquid and solid help the user of the Hazardous Materials Table to select the right entry depending on the physical form of the Aldrin. The words liquid and solid are not part of the Proper Shipping Names because they are in italics not Roman type (172.101(c)). Symbol (1) Hazardous Material Table* 172.101 Table Hazardous materials descriptions and Hazard proper shipping names class or Division (2) (3) D Aldrin, liquid 6.1 D Aldrin, solid 6.1 Dynamite, see Explosive, blasting, type A.................... Explosive, blasting, type A D PCB, see Polychlorinated biphenyls............................. AW Polychlorinated biphenyls n-Propanol or propyl alcohol normal 1.1D 9 3 FIGURE 14A Identification Numbers (4) NA2762 NA2761 UN0081 UN2315 UN1274 2. See in Italics in Column (D- Column (2) entries in italics are not part of the Proper Shipping Name. Italics are sometimes used for cross reference purposes as demonstrated in the Dynamite, see Explosive, blasting, type A and PCB, see Polychlorinated biphenyls entries in Figure 14A. The Dynamite, see Explosive, blasting, type A entry contains no information that can be used to process the shipment such as the Hazard Class, Identification Number etc.. It simply refers the user to the entry that does, the Explosive, blasting, type A entry. Dynamite may not be used as the Proper Shipping Name because it is in italics. The PCB, see Polychlorinated biphenyls entry contains no information that can be used to process the shipment. It simply refers the user to the entry that does, the Polychlorinated biphenyls entry. In this case however either PCB or Polychlorinated biphenyls may be used as the Proper Shipping Name because both appear in Roman type in Column (2) (172.101(c)(5)). 3. or in Italics In Column(21- The word or in italics permits the use ofany appropriate Roman Type Entry in the sequence as the Proper Shipping name. The n-Propanol or propyl alcohol normal entry in Column (2) of Figure 14A illustrates this point. The Proper Shipping Name would be either nPropanol or propyl alcohol normal. The or in italics permits the use of any ofthe names appearing in Roman Type as the Proper Shipping Name (172.101(c)(2)). 4. Singular vs Plural and UPPER (CAPITALVvs lower case- The Proper Shipping Name may be either in the singular or plural and in either capital or lower case letters. Explosive, blasting, type A is shown as a Proper Shipping Name in Column (2) of Figure 14A (172.101(c)(1)). Applying these exceptions the Proper Shipping Name could be any of the following: Explosive, blasting, type A; Explosives, blasting, type A; EXPLOSIVE, BLASTING, TYPE A; or EXPLOSIVES, BLASTING, TYPE A. 5. n.o.s. vs "n.o.i." or ,,no.i-bn,,- The abbreviations "n.o.i.'' which means "not otherwise indexed" or "n.o.i.b.n." which means "not otherwise indexed by name", may be used interchangeably with the abbreviation "n.o.s." which means "not otherwise specified" (172.101(c)(3)). This writer does not recommend using this exception because it is not authorized under International Dangerous Goods 14 (0691) O 1991 GSl Computer Services Inc.. Branson, MO 6S616 Reprinted with pcfmssioa AO rights reserved. ABDOO130692 Regulations and is so seldom used that it increases the probability of having problems with Carrier Acceptance and Enforcement Personnel. 6. Using IMPG or ICAO Spelling- The words ofthe Proper Shipping Name may be spelled in the same manner as they appear in the ICAO Technical Instructions or the IMDG Code. "Aluminum" may be spelled as "Aluminium" and "Sulfur" may be spelled as "Sulphur". The word "inflammable" may not be used in place of "flammable" 072.101(0)0)). For strictly Domestic shipments using 49 CFR this writer recommends spelling the Proper Shipping Name exactly the way it appears in Column (2) of the Hazardous Material Table. If using the ICAO Technical Instructions or the IMDG Code under the authority of 171.11 or 171.12 respectively, he recommends spelling the Proper Shipping Name exactly as it appears in the regulations being used. 7. Changing Order of Words in Proper Shipping Name- When a Proper Shipping Name contains qualifying words, their sequence on the shipping papers and required markings is optional. The Proper Shipping Name "Compound, polishing liquid" maybe shown as "Polishing compound, liquid" (172.101(c)(4)). This exception DOES NOT APPLY to Hazardous Wastes. AUTHORS RECOMMENDATION: Keep it exactly as shown in Column (2)- Although permitted by the regulations your author recommends that the Proper Shipping Name on the shipping papers and all required markings be EXACTLY THE SAME AS SHOWN IN COLUMN (2) of the 172.101 Table. This will reduce potential problems with enforcement and carrier acceptance personnel and limit the possibility of your shipment being frustrated or delayed while in the transportation system. THE A. B. C's OF THE TECHNICAL (n.o.s.) NAME RULE A. Technical Name (n.o.s.) Rule- The use of certain Proper Shipping Names, those listed in 172.203(k), trigger the requirement to add the Chemical or Technical Name, in parentheses, in association with the Proper Shipping Name on the Shipping Paper and when marked on Non Bulk Packages ( 172.203(k)). For the most part these Proper Shipping Names are general Hazard Class or other n.o.s. Proper Shipping Names such as Flammable liquids, n.o.s.; Infectious substances, affecting humans; Corrosive liquids, n.o.s., etc. Although not a part of the Proper Shipping Name this writer recommends that where the Technical Name Rule applies, it be considered at the same time the Proper Shipping Name is being determined for the following reasons: 1. Paragraph 172.301(b) of 49 CFR requires that the appropriate Technical Name be marked in parentheses in association with the Proper Shipping Name on non bulk packages. GSI CR: "Technical Name" Definition, 7; B. Marking, 35; B. Shipping Paper, 45 2. Paragraph 172.203(k) of 49 CFR requires that the appropriate Technical Name be entered on the Shipping Papers in association with the Basic Description in parentheses. International air and water regulations require that the Technical Name or name(s) be entered immediately after the Proper Shipping Name in parentheses on both the Shipping Papers and non bulk package markings. GSI CR: "Technical Name" Definition, 7; B. Marking, 35; B. Shipping Paper, 45 B. Three (3) General Types_Qf_Technical Name Entries- These entries will generally fall into one of three (3) types of entries: 1. Technically Pure- One Hazard Class- Name Not In the Hazardous Material Table A shipment of a Technically Pure material that is not listed in the Hazardous Materials Table (172.101 Table) by its Chemical or Technical Name MUST use the MOST APPROPRIATE Proper Shipping Name appearing in Roman type in Column (2) of the Hazardous Materials Table. If that Proper Shipping Name is one of the Proper Shipping Names contained in 172.203(k)(3), the Technical Name of the material causing it to be regulated as a Hazardous Material MUST be shown in (parentheses) as required by 172.301(b) or 172.203(k) as appropriate. A shipment of Technically Pure liquid Ethvlcyclohexane meeting the 49 CFR definition of a Class 3 would be described on the markings for a non bulk package as follows: Flammable liquids, n.o.s. (Ethylcyclohexane) 15 (0691) O 1991 GSI Computer Sovicei Inc., Bnuoo, MO 65616 Reprinted with pennmioa. All rights reserved. ABDOO130693 2. Mixture/Solution- One Hazard Class- One Hazardous Material A "mixture" or "solution", containing only one Hazardous Material and meeting the definition of only one (1) Hazard Class MUST use the MOST APPROPRIATE Proper Shipping Name appearing in bold type in Column (2) of the 172.101 Table. If that Proper Shipping Name is one of the Proper Shipping Names contained in 172.203(k)(3) the Technical Name of the material causing it to be regulated as a Hazardous Material under that Hazard Class MUST be shown in parentheses as required by 172.301(b) or 172.203(k) as appropriate. The word "contains" may be used in association with the Technical Name, if appropriate, but is not required (172.203(k)). A mixture of Acetone and other non Hazardous Materials meeting the 49 CFR definition of a Class 3 Packing Group III would be described on the markings for a non bulk package as follows: Flammable liquids, n.o.s. (Contains Acetone) or Flammable liquids, n.o.s. (Acetone) 3. Multiple Classed Materials or Mixture/Solution^Lwour More Hazardous Materials A "mixture" or "solution", containing two (2) or more Hazardous Materials or a Technically Pure material not specifically listed in the 172.101 Table meeting the definition of more than one Hazard Class, must be classified as required by 49 CFR and MUST use the MOST APPROPRI ATE Proper Shipping Name appearing in Roman type in Column (2) of the 172.101Table. If that Proper Shipping Name is one of the Proper Shipping Names contained in 172.203(k)(3), the Technical Names of at least two (2) components most predominantly contributing to the hazard or hazards of the mixture or solution MUST be shown in parentheses as required by 172.301(b) or 172.203(k) as appropriate. The word "contains" may be used in association with the Technical Name, if appropriate, but is not required (172.203(k)). A mixture of Acetone and Ethylcvclohexane meeting the 49 CFR definition of a Class 3 having a Packing Group of II would be described on the marking for a non bulk package as follows: Flammable liquids, n.o.s. (Contains Acetone, Ethylcyclohexane) or Flammable liquids, n.o.s. (Acetone, Ethylcyclohexane) A mixture of Methanol and Potassium hydroxide meeting the 49 CFR definition of a Class 3, Packing Group II and a Class 8, Packing Group II would be described on the markings for a non bulk package as follows: Flammable liquids, corrosive, n.o.s. (Contains Methanol, Potassium hydroxide) or Flammable liquids, corrosive, n.o.s. (Methanol, Potassium hydroxide) GSI CR: Subsidiary Hazard, 6; B. Subsidiary Hazard Labeling, 40 16 (0691) O 1991 GSI Coiqxaa Soviets Inc., Bransoa, MO 6S6I6 Reprinted with pemassioa All rights reserved. ABDOO130694 THE A, B, C's ofHAZARDOUS SUBSTANCES A. EPA Hazardous Substance Definition- The U.S. Environmental Protection Agency (EPA) is the agency given the primary responsibility for the determination of and establishment of regulations applying to "Hazardous Substances" under Federal Laws such as the Clean Water Act (CWA), Comprehensive Environmental Response Compensation and Liability Act (CERCLA), and the Clean Air Act (CAA). The EPA listing of Hazardous Substances can be found in 40 CFR Part 302. It can generally be said that a particular material is regulated as a Hazardous Substance because of its potential to pollute air or water if released into the environment in certain quantities. EPA, because of this potential, requires that a report be made to the National Response Center (1-800-424-8802 or 202426-2675) whenever more than a certain quantity ofthese materials is released into the environment (40 CFR 302.6). This quantity is called the "Reportable Quantity" which is commonly abbreviated as RQ. If a material has the potential to be regulated as a Hazardous Substance it will be assigned to one of the "RQ Groups" shown in Figure 17A based on the EPA's determination of the pollution potential of a specific quantity of a given material if released to the environment. ***** RQ Groups in Pounds and Kilograms ***** lib. 10 lbs. 100 lbs. 1000 lbs. 5000 lbs. .45 kg 4.54 kgs. 45.4 kgs. 454 kgs. 2270 kgs. ****************************************************** Figure 17A B. Hazardous Substance Relationship Between U.S. DOT and EPA- A Hazardous Substance is regulated by EPA because of its pollution potential not because it poses a danger while being transported in commerce. EPA has the responsibility to regulate Hazardous Substances in and out of the transportation system. The U.S. Department of Transportation (DOT) has the primary responsibility for regulating the transportation of Hazardous Materials. In many cases materials that EPA regulates as Hazardous Substances are also regulated by DOT as Hazardous Materials while in the transportation system. In order to minimize the effect of two (2) different Federal Regulatory Agencies being involved with shipments of Hazardous Substances in the transportation system, EPA and the (DOT) have agreed that the primary enforcement of Hazardous Substance requirements while in the transportation system will be done by the DOT. It should be stressed, that although enforcement within the transportation system is left to the DOT, it is still theEPAthat determines the materials and RQ which cause a particular amount of a material to be regulated as a Hazardous Substance. DOT writes and enforces regulations ensuring compliance with the EPA requirements while Hazardous Substances are being transported. C. DOT Hazardous Substance Definition- The DOT and EPA regulations are basically the same as far as the materials and RQs go. The difference is that the EPA regulations are written in terms of "total quantity" and the DOT regulations are written in terms of the "total quantity per package" or transport vehicle, if the material is not packaged. The reason for this difference is explained somewhat when one considers that in most cases materials being transported within the transportation system are going to be packaged in one form or another and will be released to the environment only if the package is broken, leaks, or is otherwise compromised. Under the DOT definition a package is regulated as a Hazardous Substance if it (the package) contains: 1. A material listed in the Appendix to 172.101. 2. In an amount that equals or exceeds the Reportable Quantity (RQ) for that material as shown in the Appendix to 172.101. 17 (0691) 1991 GS1 Computer Services Inc., Brinson, MO 65616 Reprinted with permission. All rigbts reserved. ABDOO130695 D. How To Determine Whether or Not It's A DOT Hazardous Substance- To determine whether or not a particular package is regulated as a Hazardous Substance while in the transportation system three (3) things are needed: 1. The specific chemical name(s) of the material(s) being shipped in the package; (a.) Additional Hazardous Waste Consideration- There are separate EPA Hazardous Waste D, F, and K, Number listings in the 172.101 Appendix starting after the Alphabetical listing of Hazardous Substances in List 1 of the Appendix. In making a Hazardous Substance determination for a package of Hazardous Waste, the "EPA Hazardous Waste Number" should also be checked in the appendix to 172.101. 2. The Appendix to Section 172.101 of 49 CFR; 3. The amount of the particular chemical(s) in the package in pounds or kilograms. The Appendix to Section 172.101, entitled the "List of Hazardous Substances and Reportable Quanti ties" contains two Tables listing the materials and their RQs which EPA has determined are Hazardous Substances. Table 1 covers "Hazardous Substances Other Than Radionuclides'* and Table 2 covers "Radionuclides'*. The Appendix will be found in the pages right after the Hazardous Materials Table. For the purposes of illustration, Excerpts from the Appendix to Section 172.101 are reproduced as Figure 18A below. If the material in the package: 1. Is listed in the Appendix to 172.101 AND 2. Equals or exceeds the Reportable Quantity (RQ) listed for that materialas listed in the Appendix. The package is regulated as a Hazardous Substance under 49 CFR. Excerpts from the Appendix To 172.101 Table 1- Hazardous Substances Other Than Radionuclides Hazardous Substance Synonyms Reportable Quantity (RQ) Pounds (Kilograms) Acetone* 2-Propanone 5000 (2270) Antimony trioxide 1000 (454) Benzene* 10 (4.54) Cupric Chloride' 10 (4.54) POLYCHLORINATED BIPHENYLS (PCBs) Aroclor 1016 1 (.454) `Means that this name is listed as a Proper Shipping Name in the HMT-172.101 FIGURE 18A Illustration: A 55 gallon drum of Acetone weighing 200 kg (441 lbs) would not be regulated as a Hazardous Substance. Although reference to Figure 18A indicates that Acetone is listed in the Appendix, the amount in the package does not equal or exceed the RQ of 2270 kg (5000 lbs) listed for Acetone. On the other hand, 11,355 L (3000 gals) of Acetone weighing 10,886 kg (24,000 lbs) being shipped in a Cargo Tank (One Package) would be regulated as a Hazardous Substance because the package (the Cargo Tank) contains a material that is listed in the Appendix in an amount that equals or exceeds the RQ listed 2270 kg (5000 lbs). 18 (0691) 1991 GSI Consuls Soviets Inc., Bnuoa, MO 6S616 Reprinted witt ptimrttion All rijha reeerved. ABDOO130696 E. If It Is a DOT Hazardous Substance It Is Regulated Bv 49 CFR- Any package meeting the definition of a Hazardous Substance is regulated at all times while in the transportation system. 1. Hazardous Substance Meeting the Definition of a 49 CFR Hazard Class- A package containing a Hazardous Substance that ALSO meets the definition of a DOT Hazard Class must be shipped using that Hazard Class and an appropriate Proper Shipping Name selected from the Hazardous Materials Table in accordance with all the requirements of 49 CFR applicable to that Proper Shipping Name and Hazard Class. In addition, the package must also be in compliance with all the additional Hazardous Substance requirements of 49 CFR that apply. Reference to the Appendix to 172.101 indicates that a 11,355 L (3,000 gals) Cargo Tank of Acetone weighing 10,886 kg (24,000 lbs) is regulated as a Hazardous Substance. Acetone has a Flash Point of -17.8C (CPF) and is regulated under the DOT Hazard Class of 3, Packing Group II. It must be shipped using the Proper Shipping Name of Acetone and the Hazard Class of3; in full compliance with all the requirements of49 CFR applicable to Acetone, 3; AND must have the letters RQ on the Shipping Paper either before or after the Basic Description to meet the 49 CFR requirements applicable to Hazardous Substances (172.203(c)(2)). The drum must be shipped, however, in full compliance with all the requirements of 49 CFR applicable to Acetone. The letters "RQ" should not be marked on the package or entered on the Shipping Paper because the package is not regulated as a Hazardous Substance. 2. Hazardous Substance Not Meeting the Definition of a 49 CFR Hazard Class- A Hazardous Substance that DOES NOT meet the definition of a DOT Hazard Class and is not a Hazardous Waste, MUST be classed as a Class 9, and offered for transportation using one of the following Proper Shipping Names: Environmentally hazardous substances, liquid, n.o.s. Environmentally hazardous substances, solid, n.o.s. Other regulated substances, liquid, n.o.s. Other regulated substances, solid, n.o.s. In addition it must be offered in compliance with all the Class 9 and Hazardous Substance requirements of 49 CFR that apply. Illustration: Reference to Figure 18A or Table 1 to the Appendix to Section 172.101 indicates that a 544 kg (1200 lb) package of "Antimony trioxide" powder is regulated as a Hazardous Substance. "Antimony trioxide" does not meet the definition ofany Hazard Class. The shipment ofa 544 kg (1200 lb) package of "Antimony trioxide" would be classed as a Class 9 and shipped using the Proper Shipping Name Environmentally hazardous substances, solid, n.o.s. and otherwise packaged, marked, labeled, and documented as required by 49 CFR for that Proper Shipping Name. A 408 kg (900 lb) package of "Antimony trioxide" is not regulated as a Hazardous Substance and is not subject to the Hazardous Material regulations contained in 49 CFR. F. Specific ADDITIONAL DOT Hazardous Substance Requirements- In addition to the 49 CFR requirements generally applicable to the Proper Shipping Name, Hazard Class, Packing Group, and quantity of material being shipped there are ADDITIONAL Hazardous Substance marking require ments for non bulk packages (172.324) and additional Hazardous Substance entries required on the Shipping Papers (172.203(c)) for both Non Bulk and Bulk Packages of DOT Hazardous Substances. The specific DOT Hazardous Substance requirements are summarized in Chart Form in Figure 20A on page 20 and will be covered in detail in the Marking and Shipping Paper portions of this Text. GSI CR: F. Marking, 37; C. Shipping Paper Entries, 48 International Shipments of Hazardous Substances- Although 49 CFR generally permits the use of other regulations for shipments of Hazardous Materials between the U.S. and Canada and for the air and water transportation of Dangerous Goods, it does so only if certain conditions are met. One of those conditions will be compliance with the Additional Hazardous Substance Requirements of 49 CFR (171.11(d)(1) for ICAO Air, 171.12(b)(4) for the IMDG Code; and 171.12a(b)(10) for the Canadian TDG Regulations). 19 (0691) O 1991 GSI Computer Services lac., Brdsoo, MO 65616 Reprinted with pgmwini All rights reserved. ABDOO130697 ADDITIONAL D.O.T. HAZARDOUS SUBSTANCE REQUIREMENTS Specific Hazardous Substance Requirements Non Bulk Bulk Packaging Packaging 1. RQ Marked on Package (172.324(b)). Yes No 2. The Name of Hazardous Substance constituent as listed in Appendix to 172.101 marked on the package in parentheses if not part of the Proper Shipping Name (172.324(a)). Yes No or IF a Hazardous Waste 2. "F" or "K" Waste Stream Number or "D Number" or "EPA------ "marked on package in parentheses as appropriate. Yes No 3. RQ Entered on Shipping Paper either before or after the Basic Description (172.203(c)(2)). Yes Yes 4. Name of the Hazardous Substance Consti tuents) entered in parentheses on the Shipping Paper if not part of the Proper Shipping Name (172.203(c)(1)). Yes Yes or if a Hazardous Waste 4. "F" or "K" Waste Stream Number", "D Number", or "EPA------ " entered in parentheses on the Shipping Paper as appropriate. 5. Carrier Discharge Notification (40 CFR 302.6(a)). Yes Yes Yes Yes Replace rt------" with "corrosivity", "ignitability", "reactivity" or"toxicity" as appropriate. FIGURE 20A G. Carrier Hazardous Substance Discharge Notification- When a DOT Hazardous Substance is discharged from a package or transport vehicle while in the transportation system the Carrier (Person In Charge) must notify the National Response Center of the discharge as soon as they have knowledge of it. The notification must be telephoned to 1-800-424-8802 or 202-267-2675 and must contain the information required by 40 CFR 302.6. Although while in the transportation system, this is primarily a Carrier responsibility your author strongly recommends that Shippers ensure the report is made. In addition, it would be a good idea to require the Carrier to notify them concurrently with notification to the National Response Center. H. 40 CFR WARNING: It is your author's opinion that the reporting requirements of 40 CFR 302.6 require a report to be made whenever a Hazardous Substance designated in 40 CFR Part 302 is discharged in an amount that equals or exceeds the RQ for that substance as designated in that Part. 49 CFR creates additional requirements for Marking and Shipping Paper entries forthose materials listed in the 172.101 Appendix ONLY. It does not control the reporting requirements or Hazardous Substances not in the Appendix. In the Note to 171.15 DOT acknowledges that 40 CFR 302.6 does. If EPA has designated a material and RQ in 40 CFR 302 that is not reflected in the 172.101 Appendix or the 49 CFR definition of a Hazardous Substance, a Discharge Report must be made even though that material is not regulated as a Hazardous Substance under 49 CFR. Illustration: If the contents of 20 drums of Acetone, each containing 220 kg (440 lbs) of Acetone were released, 40 CFR 302.6 requires that the Discharge Report be made. Under 49 CFR, each of the 20 Packages is not regulated as a Hazardous Substance. Confusing and inconsistent? Yes. Must the Discharge Report still be made? Yes! 20 (0691) O 1991 GS! Computer Service* toe., Bnnsoo, MO <5616 Reprinted with permmioo. All rigid* reserved. ABDOO130698 The A. B. Cs ofHAZARDOUS WASTEIPENTIEICATION FOR TRANSPORTATION A. 49 CFR Definition of a Hazardous Waste- 49 CFR defines a "Hazardous Waste" as any material that is subject to the Hazardous Waste Manifest requirements of the Environmental Protection Agency (EPA) specified in 40 CFR Part 262 (171.8). If there is no EPA manifest requirement there is no regulation by DOT as a "Hazardous Waste" under 49 CFR. On the other hand if EPA requires a Uniform Hazardous Waste Manifest for the material being transported under 40 CFR Part 262, the material is a "Hazardous Waste". Said another way, a Hazardous Waste under 49 CFR is whatever EPA and 40 CFR says it is. B. When Does 40 CFR Part 262 Require the Use of A Manifest? A Generator (Shipper) must prepare the Uniform Hazardous Waste Manifest according to the instructions contained in the Appendix to 40 CFR Part 262 whenever they transport or offer for transportation a Hazardous Waste for off site disposal, treatment, or storage (40 CFR 262.20(a)). C. 40 CFR Definition of a SOLID WASTE- A Solid Waste is any discarded material which is not otherwise excluded from being a Solid Waste by 40 CFR (40 CFR 261.2(a)(1)). It has nothing to do with its physical form. A "Solid Waste" is any material that is being discarded regardless of its physical form gaseous, liquid, or solid. P. When Is a Material Being DISCARDED? A material is being discarded when it is: 1. Abandoned- A material is abandoned by being disposed of, burned or incinerated or accumulated, stored, or treated (but not recycled) before or in lieu ofbeing abandoned by being disposed of, burned or incinerated (40 CFR 261.2(b)). As a general rule if the material is going to be disposed or burned, it is being abandoned. Illustration: A 55 gallon drum of liquid "Acetone" being shipped for incineration is a solid waste. or 2. Recycled- A material that is recycled or accumulated, stored or treated before recycling as specified in 40 CFR 261.2(c)). Exclusions for certain materials and situations are contained in 40 CFR 261.2(e)). or 3. Inherently Waste-like- Materials having Hazardous Waste Numbers F020, F021, F022, F023, F026, F028, or any other material added to the list in accordance with 40 CFR 261.2(d) that is being recycled. E. 40 CFR Definition of a Hazardous Waste- In general terms, the EPA defines a "Hazardous Waste" as a "Solid Waste" that is not otherwise excluded from being a Hazardous Waste under 40 CFR that either: 1. Is listed in Subpart D of Part 261 of 40 CFR f40 CFR 261.3faW2. a. Bv name as being an AcuteJHazardous Waste in 40 CFR 261.33(e). Solid wastes that are listed by name in 40 CFR 261.33(e) are Acute Hazardous Wastes. Generally these wastes will have an EPA Hazardous Waste Number prefixed with a "P" such as Aldrin-P004, Hydrogen cyanideP063, or Zinc cyanide-P121. b. By name as a Toxic or otherwise designated wasteiniO CFR 261.33(f), Solid wastes that are listed by name in 40 CFR 261.33(f) are Hazardous Wastes. Generally these wastes will have an EPA Hazardous Waste Number prefixed with a "U" such as Acetone-U002, Benzene- U019 or 1,1,2,Trichloroethane- U227. Both a. and b. above include listed materials which are formulated or manufactured for commercial or manufacturing use including the material in its commercially pure or technical grade and all formulations in which the material is the sole active ingredient. Although it includes the residue or contaminated soil, water, or debris resulting from the cleanup or spill of any of the 21 (0691) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with perantioa. All rigbts reserved. ABDOO130699 materials listed, it does not include a material such as a manufacturing process waste that contains any of the materials listed (40 CFR 216.33(d) and Comment following). Where a manufacturing process waste is deemed to be a Hazardous Waste because it contains a listed substance it will be either listed as a Hazardous Waste from a Non Specific Source (261.31) or as a Hazardous Waste from a Specific Source (262.32). c As a Hazardous Waste from Non Specific Sources in 40 CFR 261.31- Solid wastes that are listed by name in 40 CFR 261.31 are Hazardous Wastes from non specific sources. Generally these wastes will have an EPA Hazardous Waste Number prefixed with a "F" such as F003 for a solid waste that is a used non-halogenated solvent like "Acetone". d. As a Hazardous Waste from Specific Sources in 40 CFR 261.32- Solid wastes that are from a source listed by name in 40 CFR 261.32 are Hazardous Wastes from specific sources. Generally these wastes will have an EPA Hazardous Waste Number prefixed with a "K" such as K003 for a solid waste that is "wastewater treatment sludge from the production of molybdate orange pigments". OR 2. Exhibits anv ofthe characteristics ofHazardous Wastes identified in SubpartCof40 CFR (40 CFR 261.3(a)(2)). a. Characteristic of Ignitabilitv- A solid waste exhibiting any ofthe following general characteristics is regulated as a Hazardous Waste and has the EPA Hazardous Waste Number of D001: (1). Liquids that have a flash point of less than 60C (140F) (40 CFR 261.21(a)), or (2). Is not a liquid and can cause fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited bums so vigorously and persistently that it creates a hazard, or (3). Is a Division 2.1 (Flammable Gas) under 49 CFR 173.115, or (4). Is a Division 5.1 (Oxidizer) under 49 CFR 173.127. b. Characteristic ofCorrosivity- A solid waste exhibiting any ofthe following general characteristics is regulated as a Hazardous Waste and has the EPA Hazardous Waste Number of D002: (1). Is aqueous and has a pH less than or equal to 2 or greater than 12.5 (40 CFR 261.22(a)), or (2). Is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inches) per year at a temperature of 55C (130F) (40 CFR 261.22(a)). c. Characteristic of Reactivity- A solid waste exhibiting any ofthe following general characteristics is regulated as a Hazardous Waste and has the EPA Hazardous Waste Number of D003: (1). Reacts violently or forms a potentially explosive mixture with water, generates toxic gases, vapors, or fumes in sufficient quantities to present a hazard to health or the environment when mixed with water, or is normally unstable and readily undergoes violent change without detonating (40 CFR 261.23(a)). (2). Is a forbidden explosive as defined in 49 CFR 173.54; defined by 49 CFR as a Divisions 1.1, 1.2, or 1.3 (Class A or B explosives) in 49 CFR 173.50; it is readily capable of explosive decomposition or reaction at standard temperature and pressure; or other characteristics contained within 40 CFR 261.23 (a). 22 (0691) C 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with permission. All rigba reserved. ABDOO130700 d. Characteristic ofToxicity- A solid waste exhibits the characteristic ofToxicity if, using the Toxicity Characteristic Leaching Procedure Test (TCLP) in Appendix II to 40 CFR Part 261, the extract from a representative sample of the solid waste is determined to contain any of the contaminants listed in Table 1 of 40 CFR 261.24 at a concentration equal to or greater than the value shown for the contaminant in Table 1 (40 CFR 261.24(a)). There is a list of over 38 different contaminants listed in Table 1. Each has its own EPA Hazardous Waste Number prefixed with a "D", starting with D004- Arsenic. F. Exclusions- The following general exclusions could apply. The 40 CFR reference given should be consulted for specific applicability. It should be stressed that although these exclusions might exclude something from being regulated as a Hazardous Waste under 40 CFR, any such materials meeting the definition of a Hazardous Material under 49 CFR will be regulated as such while in the transportation system. 1. Samples- As a general rule, samples being sent to a laboratory for analysis as to their composition or characteristics (261.4(d)) and for treatability studies (261.4(e) and 261.4(f)) are excluded when collected, processed, and offered for transportation as required by the applicable regulations. GSI CR: 49 CFR Sampling Relief, 172.101(c)(ll) 2. Residues in_empty containers- Any residue ofa Hazardous Waste remaining in a container from which all the wastes have been removed using the practices commonly employed to remove materials from that type of container, e.g. pouring, pumping, aspirating etc., is not a Hazardous Waste if: a. The container contains no more than 2.5 centimeters (T) on the bottom; or no more than 3% by weight of the total capacity of the container remains if the container is less than or equal to 110 gallons in size, or no more than .3% by weight of the total capacity ofthe container remains if the container is greater than 110 gallons in size. GSI CR: DOT Definition of Residue, 171.8; Empty (Residue) Packagings, 173.29 b. The container that has held a Hazardous Waste that is a compressed gas is empty when the pressure in the container approaches atmospheric. c. Containers containing an Acute Hazardous Waste listed in 261.31, 261.32, or 261.33(e) is processed as required by 40 CFR 261.7(b)(3). 23 (0691) O 1991 GSI Computer Services be., Bisson, MO 65616 Reprinted with peransioo. All rigbs reserved. ABDOO130701 RESERVED- Intentionally left blank. Please turn to page 25. 24 (0691) O 1991 GSI Confute* Soviet* lac., Bnmoo, MO 656)6 Reprinted with pennteioa. All rights moved ABDOO130702 THEA.B. C's OFPACKAGINGTERMINOLOGY Terminology plays an important part in understanding the packaging process. The differences between "packaging", "package", and "Overpack" as well as the different types of packagings is critical when working with the packaging process. Let's take a logical step by step look at some of the terms we will be using. A. Packaging- Receptacles (Containers) AND any other components necessary for the receptacle to perform its containment function and meet the packaging requirements of Parts 171-180 of 49 CFR. For the most part these receptacles, components, and other requirements are contained within Part 173 of 49 CFR. The "Packaging Authorizations "Columns (8A)-(8C) of the Hazardous Materials Table refer to Sections within Part 173 containing one or more authorized packagings that may be used to package the Hazardous Material covered by the entry. In addition, other "General Packaging'* requirements such as cushioning materials, are contained elsewhere in 173.24, 173.24a, Column (7) Special Provisions, etc.. Items (a)-(c) in Figure 25A illustrate examples of different non bulk packagings (171.8). GSI CR: H.-I. Columns (7)-(8), 3; C. & D. Packaging Selection, 28 C3 FIGURE 25A rs>---------- ^ (a) <b) (c) (e) 1. Combination Packaging- One or more inner packagings used in combination with a non-bulk outer packaging. It does not include a composite packaging. In Figure 25A, the combination of Inner Packaging (b) with Outer Packaging (c) results in Combination Packaging (d) (171.8). (a). Outer Packaging- The outermost packaging (enclosure) ofa combination or composite packaging together with any cushioning or absorbent materials and any other components necessary to protect and contain the inner packagings or receptacles. In Figure 25A, box (c) is an example of an Outer Packaging. (b). Inner Packaging- A packaging for which an outer packaging is required. It does not include the inner receptacle of a composite packaging. In Figure 25A, plastic bottle (b) is an example of an Inner Packaging. 2. Single Packaging- A non bulk packaging other than a combination packaging. Generally this consists ofa single receptacle (packaging) into which the material is loaded. Drum (a), in Figure 25A, illustrates a Single Packaging. 3. Composite Packaging- A packaging consisting of an outer packaging and an inner receptacle constructed so that the inner receptacle and outer packaging form an integral packaging. Once assembled it remains an integrated single unit and is filled, stored, transported, and emptied as such (171.8). A drum with a liner is an example of a composite packaging. B. Package- The total result of the packaging process including all required packaging(s) plus the Hazardous Material (contents) closed and ready for marking and labeling (171.8). Item (d), in Figure 25A, illustrates a Package. The contents have been added and all required packagings have been assembled, closed and 25 (0691) O 1991 GSI Confute? Services Inc., Branco, MO 656)6 Reprinted with permaske. All rights reserved. ABDOO130703 are ready for marking and labeling (171.8). Item (d) in Figure 25A is a "Combination Package" because "Combination Packaging" was combined with the contents. When the contents are added to drum (a) in Figure 25A and all the openings are properly closed the result will be a "Single Package" because "Single was combined with the contents. C. Overpack- An Oveipack is an enclosure that is used by a single consignor to provide protection or convenience in the handling of a package or to consolidate two or more packages (171.8). Item (e) in Figure 25A illustrates the overpacking of two of the Item (d) Combination Packages into one enclosure for the purposes of consolidation. GSI CR: K. Overpack Marking, 38 It should be stressed that each package in the Overpack must be in full compliance with all applicable packaging regulations, properly marked, labeled, and eligible in all respects to be transported by itself. In addition each package must be placed in the oveipack and the outside of the Oveipack marked and labeled as required by 173.25. In general this will require that all: 1. The Marks and Labels on each of the packages overpacked be reproduced on the outside of the overpack unless the Marks and Labels on the overpacked packages are visible from the outside of the Overpack (173.25(a)(2)). 2. The packages subject to the orientation markings of 172.312 be placed in the overpack with their filling holes upward and that the oveipack be marked on two opposite vertical sides with the orientation marking arrows required by 172.312 (173.25(a)(3)). 3. Overpacks of Specification Packagings be marked with an indication that the oveipacked packages inside comply with prescribed specifications unless the Specification Markings on the overpacked packages are visible from the outside of the Overpack (173.25(a)(4)). 4. Packages containing Class 8 or Division 5.1 materials in Packing Group I may not be overpacked with any other material (173.25(a)(5)). 26 (0691) O 1991 GSI Computer Services lac., Branson, MO 6S616 Reprinted with permmioa. All rights reserved. ABDOO130704 THE A. B. Cs OF PACKAGING A. Determine The Quantity Per Package To Be Shipped- The quantity per package plays a big part in the packaging process. It plays a very important part in selecting packaging which is efficient for the quantity of material being shipped. Among other things the total quantity per package and quantity per inner packaging can determine such things as whether or not the package is regulated as a Hazardous Substance, eligible for exceptions, and applicability of Special Provisions. This information is absolutely critical for using Columns (9A) and (9B) of the Hazardous Material Table and 173.27(f) to package the Hazardous Material being shipped by air under 49 CFR. As one of the initial steps of the packaging process your author recommends that the total amount per package and quantity per inner packaging be determined. In determining quantities the metric (SI) system is used (171.6(a)). GSI CR: Metric Conversion Chart, Appendix V Illustration: We are packaging a 4 L (Liter) package ofAcetone. The Acetone is to be packed in two (2) 2 L glass bottles (Inner Packagings) which will in turn be packed in a Fiberboard Box. Hazardous materials Proper Shipping Names (2) Acetone Hazardous Material Table - 172.101 Table Pack ing group (5) Special Provis. (7) Non Bulk Bulk Pass. Cargo Vessel Other Excep- Pack- Pack- Aircraft Aircraft Stow Provisions tions agings agings Railcar Only age (8A) (8B) (8C) (9A) (9B) (10A) (10B) n T8 150 202 242 5 L 60 L B Calcium hydride Corrosive solids, n.o.s. I I n m A19 None 211 N40 None 211 154 212 154 213 242 Forbidden 15 kg E 240 1 kg 25 kg B 240 15 kg 50 kg A 240 25 kg 100 kg A FIGURE 27A M3 M3 M3 B. Select the Packaging Authorization Section- Each Hazardous Material must be packaged in accordance with the packaging requirements of 49 CFR. This starts with ensuring that any packagings selected to package the Hazardous Material is authorized for the material being shipped by one of the "Packaging authorizations" in Columns (8A)-(8C) of the Hazardous Materials Table entry applicable to the material being packaged. All numbered references (authorizations) in these Columns refer to Sections within Part 173 of 49 CFR. Columns (8A) and (8B) generally apply to Non Bulk Packaging and Column (8C) applies to Bulk Packagings. GSI CR: I. Column (8), 3 Illustration: Reference to Columns (8A)-(8C) of the Hazardous Materials Table or Figure 27A for the Acetone entry indicates that the Packaging Exceptions will be authorized in 150 (173.150), Non Bulk Packaging authorized in 202 (173.202), and the Bulk Packaging authorized in 242 (173.242). Reference to Columns (8A)-(8C) of the Hazardous Materials Table or Figure 27A for the Calcium hydride entry indicates that No Packaging Exceptions are authorized for that material because the word "None" appears in Column (8A). It further indicates that Non Bulk Packaging is authorized in 211 (173.211), and the Bulk Packagings authorized in 242 (173.242). Packing Group Impact- For entries in the Hazardous Materials Table with more than one Packing Group, such as the Corrosive solids, n.o.s. entry in Figure 27A, the selection of the Packaging Authorization Section depends on the Packing Group in Column (5) of the Hazardous Materials Table. Ifthe Corrosive solids, n.o.s. is a Packing Group I, reference to Columns (8A)-(8B) for that Proper Shipping Name and Packing Group entry indicates that No Packaging Exceptions are authorized for that material because the word ''None" appears in Column (8A). It further indicates that Non Bulk Packaging is authorized in 211 (173.211). On the other hand ifCorrosive 27 (0691) O 1991 GSI Couyuter Services Inc., Branson, MO 65616 Reprinted wiib pcnmaoo. Ail rights reserved. ABDOO130705 solids, n.o.s. is a Packing Group II, reference to Columns (8A)-(8B) for that Proper Shipping Name and Packing Group entiy indicates that Packaging Exceptions are authorized in 154 (173.154) and that the Non Bulk Packaging is authorized in 212 (173.212). C. Packaging Selection- Normally, absent the use of an exception, the packaging to be used to package the material must be authorized for the material in the appropriate Packaging Authorization Section to which referred by entries in Columns (8B)-(8C) (173.24(c)). These Sections are all located in Part 173 of49 CFR. A Column (8B) reference to 202 is a reference to 173.202. Normally, as illustrated by Figure 28A, the Packaging Authorization Section for Non Bulk Packagings will be separated into Combination Packagings and Single Packagings. The numbers and letters after some of the packagings such as the "Fiberboard box: 4G" and the "Steel Drum: 1A1" refer to UN Specification Packaging. GSI CR: E. UN Specification Packaging Indications and Codes, 29; H. Exceptions, 31 Illustration: Reference to 173.202 for the packaging to be used for Acetone indicates that it may be packaged in Glass Inner Packagings inside a "4G" Fiberboard box. A combination package containing two (2) 2 L glass bottles of Acetone inside a UN 4G Fiberboard Box is authorized (173.202(b)). This Section would also permit the transporta Excerpts From 173.202 tion of 20 L of Acetone in a Single Packaging 173.202 Non-Bulk packagings for liquid consisting ofa "1A1" Steel Drum providing it was hazardous materials in Packing Group II not being offered for or transported on passen ger aircraft (173.202(c)). (b) The following combination packagings are authorized: D. General Packaging Considerations- Each packag ing must meet the applicable general packaging requirements contained in Subpart B of Part 173, the performance level requirements of Part 178 as appropriate for the Packing Group being packaged, OuterPackagings: Steel drum: 1A1 or 1A2 Plywood box: 4D Fiberboard box: 4G and comply with the packaging requirements of any applicable Special Provisions listed for the entry in Column (7) of the Hazardous Materials Table. GSI CR: H. Column (7), 3 Inner Packagings: Glass or earthenware receptacles Plastic receptacles Metal receptacles 1. Examples of SOME Common General Packag Glass ampoules ing Requirements (c) Except for transportation by passenger a. All Packages all the time- Each package used aircraft, the following single packagings to transport Hazardous Materials must be are authorized: designed and constructed and have its con tents so limited that under conditions nor mally incident to transportation there will be Steel drum: 1A1 or 1A2 Plastic Drum: 1H1 or 1H2 no release of the material to the environment and its packaging integrity will not be compro FIGURE 28A mised (173.24(b)). b. Compatibility-Permeability- All packagings used must be compatible with the material, particularly as applies to corrosivity, permeability, softening, premature aging, and embrittlement (173.24(e)). c. Outage - Outage is the space between the liquid level and the top ofthe receptacle. This space allows for expansion ofthe material. Liquids must not completely fill a receptacle at a temperature of 55oC (131oF) or less (173.24a(d)). d. Cushioning and Securing- Inner packaging of combination packagings must be so packed, cushioned, and secured so as to prevent their breakage or leakage and to control their movement within the outer packaging under conditions normally incident to transportation (173.24a(a)(3)). WARNING: These are just some of the more common general packaging requirements applicable to non bulk packagings. Subpart B of Part 173 particularly Section 173.24, 173.24a for non bulk packagings, 173.24b for bulk packagings, 173.26 for quantity limitations, and 173.27 for air transportation under 49 CFR must be carefully checked. 28 (0691) O 1991 GSI Computer Services Inc., Bramoo, MO 65616 Reprinted with peraossioa All rights reserved. ABDOO130706 G. UN Specification Package Indications and Codes 1. UN Indication - The package must be marked with the "UN Symbol" (Brand), the letter "u" over the top of the letter "n" inside a circle. In lieu ofthe "UN Symbol" just the letters UN may be applied (marked) on metal receptacles (49 CFR 178.503(a)(1)). GSI CR: UN Performance Oriented Packaging, Appendix I, Page 15 2. Packaging Type Code, Material of Construction Code, and the Cate gory Within Type Code: The Type ofPackaging will be indicated by an Arabic number such as the number 1 for a drum or the number 4 for a box. The material that the packaging is constructed from will be indicated by an UPPER CASE Latin letter such as the letter A for steel or the letter G for Fiberboard. A UNIA is a steel drum. A (n) 4G is a Fiberboard Box. In some cases such as barrels, drums, and jerricans, there is a number which indicates the category of a container within a certain Type and Material. In marking drums and jerricans, a "closed head" container would be indicated by the number 1 and an "open head" container would be indicated by the number 2 marked immediately after the Material of Construction Code. A drum marked UN1A1 would be a closed head steel drum and a drum marked UN1A2 would be an open head steel drum. Figure 29A below contains a summary of the more commonly used Packaging Types, Materials, and Category Codes. Tvoe Drums Barrels Jerricans Boxes Bags Composite Packagings Tvpe-Material-Category Table Material Category A Steel B Aluminum C Natural Wood D Plywood F Reconstituted Wood G Fiberboard H Plastic L Textile M Paper, multiwall N Metal other than steel or aluminum P Glass Porcelain, or stoneware. FIGURE 29A A. B. or H Drums-Jerricans 1 Closed Head 2 Open Head A or B Boxes 1 Ordinary A or B 2 A or B w/inner liner or coating C_Boxes 1 Ordinary 2 w/sift proof walls H Boxes 1 Expanded Plastic 2. Solid Plastic L Bqgs 2 Sift proof 3. Water Resistant MBags ____2 Multi wall, water resistant_____ 3. Composite Packaging- When dealing with Composite Packagings two (2) letters are used, in sequence, for the Material Code. The first letter indicates the material of the inner receptacle and the 2nd indicates the material of the outer packaging. A UN6HA1 is a Composite Packaging consisting of a plastic inner receptacle in a steel drum. For combination packagings only the codes for the outer packaging is used. The Inner Packagings may be metal, glass, etc. and there will generally be no indication of their type or construction marked on the outside of the package. 29 (0691) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with penrission. All rights reserved. ABDOO130707 F. UN Specification vs Non Specification Packaging Packagings are either "Specification** or "Non Specification*'. UN specification packagings are packagings which meet certain governmental requirements covering minimal construction and material requirements and the ability to pass applicable UN Performance Tests. In 49 CFR the UN construction and materials requirements will be found starting at 178.504 and the UN Packaging Performance Tests will be found in Subpart M of Part 178. If the packagings or completed package, as appropriate, meet the prescribed requirements, they may be marked with the Specification Mark showing they have qualified under the appropriate specification. Under the UN Specification Packaging scheme all UN Specification Packages will have the prescribed ----------------------------Illustrations of Common UN/ICAO Markings-------------------------------- UN1A1/Y/150/91 USA/GSI1234 A UN 1A1 closed head steel drum, tested to Packing Group 11 standards. No Relative Density entry is shown so it may only be used for materials with a realtive density not exceeding 1.2. The drum was tested under the Hydro static Pressure Test to 150 kilopascals (21.75 psi), was manufactured in 1991 and was marked under the authorization of the USA . The GSI is the symbol of the person authorizing the marking of the package with the UN markings and the numbers 1234, identify a particular packaging type or design. UN6HA1/Y1.4/250/91 USA/GSI1233 A UN6HA1 composite packaging, 6, consisting of a plastic inner receptacle, H, inside a closed head steel drum, Al. The packaging has been tested to Packing Group II standards, is suitable for materials with a Relative Density of up to 1.4, was tested under the Hydrostatic Pressure Test to 250 kilopascals (36.26 psi), was manufactured in 1991, and was marked under the authorization of the USA . The GSI is the symbol of the person authorizing the marking of the package with the UN markings and the numbers 1233, identify a particular packaging type or design. ZlT\4G/X30/S/91 \jny USA/GSI 1232 A UN 4G Fiberboard box, tested to Packing Group I standards for a maximum Gross Weight of 30 kgs (60Lbs). It is intended only for Solids or inner packagings, was manufactured in 1991, marked under the authority of the USA. The GSI is the symbol of the person authorizing the marking of the package with the UN markings and the numbers 1232, identify a particular packaging type or design. FIGURE 30A UN Specification mark on the required "outside packaging*' of the package. Examples of some of the more commonly used UN packagings are contained in Figure 30A and 178.503(d)). As a general rule, under the UN system there is no requirement that the "inner packagings'' used in "combination" packages be marked with any UN Specification Mark. Non Specification Packagings just have to meet the applicable General Packaging Requirements of Subpart B of Part 173, applicable Special Provisions specified in Column (7), and other requirements contained in the Packaging Authorization authorizing the use of the non specification packaging and will generally have no UN Specification marks on them. In most cases the "limited quantity" packagings contained in Exception Packaging Authorizations will be non specification packagings. They will be described within the Packaging Section in general terms such as a "glass", "metal", or "fiberboard box" with no UN Specification Packagings specified. GSI CR: D. General Packaging Considerations, 28 30 (0691) O 1991 GSI Computer Soviets Inc., Branson, MO 65*16 Reprinted with penmssioa. All rights reserved. ABDOO130708 G. UN Performance Oriented Packaging Tests - Overview- The standard UN Performance Ori ented Packaging tests and the general purpose of each is as follows: Test Type (49 CFR Reference! Ability ofPackage/Packaging To Drop (178.603) Contain and protect the Dangerous Goods if the package is dropped. Leak proofness (178.604) Prevent leakage of liquids under conditions of normal transport. Stacking (178.606) Maintain stability w/in a stack while stacked with similar type packages. Hydrostatic Pressure (178.605) Prevent leakage of liquids under pressure. Vibration Standard (178.608) Withstand vibrations without rupture or leakage (USA Only) . Reader Note: For a full discussion of UN Performance Packaging see Appendix I. H. Exceptions- Generally packaging exceptions, if any, are contained in the Sections in Part 173 referred to by the Packaging Authorizations in Column (8A) of the Hazardous Materials Table. It can generally be said that if Column (8A) says "None", there is no packaging exception authorized for the material. 1. Limited Quantities- The term Limited Quantity (Ltd Qty) as used in 49 CFR does not mean the same thing as when used in the International Maritime Dangerous Goods Code or the ICAO Technical Instructions For The Safe Transport of Dangerous Goods By Air. As used in 49 CFR the term means a material that is packaged in accordance with a "limited quantity" paragraph or sub paragraph contained within the Packaging Section to which you are referred by Column (8A) of the Hazardous Materials Table for the entry. Generally the Limited Quantity paragraph will be (b) in this Section and start off with wording such as "Limited quantities of'. If Column (8A) does not contain an Exception Authorization for a particular entry or if the Hazardous Material is not packaged in the manner and quantity prescribed by the "limited quantity paragraph" the material may not be offered for shipment as a "limited quantity." GSI CR: B. Ltd Qty Shipping Paper entry, 47 Illustration- Can a 2 L glass bottle of Acetone, a Class 3 Packing Group II material, packaged inside a strong outside container (fiberboard box) be offered for transportation as a "limited quantity"? Reference to Column (8A) for the Acetone entry in the Hazardous Materials Table or Figure 27A on page 27 indicates the "Exceptions" for Acetone can be found in Section 173.150. The "limited quantity paragraph" in Section 173.150 is paragraph (b) (173.150(b)). A comparison of the packaging being used against the packaging indicated in Subparagraphs (1)(3) of 173.150(b) indicates the package IS NOT eligible to be offered as a "limited quantity" because it is not packaged in accordance with the "limited quantity paragraph". Under this Exception Authorization the maximum amount of a Packing Group II material per inner packaging is limited to 1 Leach. The 2 L glass bottles are not eligible. What IF the two (2) 2 L glass bottles were replaced with four (4) 1 L glass bottles? By following the same sequence as above we would determine the NEW packaging meets the requirements and would be eligible to be offered and transported as a "limited quantity" (173.150(b)(2)). a. Limited Quantity Benefits- Shipments eligible to be shipped as limited quantities are generally excepted from one or more of the requirements of 49 CFR such as labeling, DOT Specification Packaging, Placarding, etc. These exceptions (benefits) can result in substantial cost savings and increased transportation efficiency, particularly by highway. As a general rule, the exceptions (benefits) are listed in the "paragraph" preceding the packaging requirements which are normally contained in the "subparagraphs". Reference to 173.150(b) in 49 CFR would indicate that packages eligible to be shipped as a Limited Quantity would be excepted from labeling, specification packaging, and Placarding when transported by all modes except air. When transported by air, UNDER 49 CFR, only the exceptions for specification packaging and Placarding apply and all packages must be labeled. It should be 31 (0691) O 1991 GSI Computer Services lac., Bnuoa, MO 6S616 Reprinted with pcrmmioa AU rights reserved. ABDOO130709 noted that although the packaging does not have to be UN Specification Packaging, that all packagings and packages, including those for which there is an exception must meet the general packaging requirements contained in Subpart B of Part 173. It MUST BE STRESSED that the "benefits" can fluctuate from one "limited quantity paragraph and material" to another and, as noted above, even within the same paragraph depending on the mode of transportation used. The limited quantity benefits for Class 3 materials contained in 173.150(b) are different from the limited quantity benefits for Division 6.1 materials contained in Section 173.153(b). As with any exception or exemption, an analysis, similar to the above, should be conducted to ensure the shipment does not exceed the scope of the relief provided. GSI CR: B. Ltd Qty Shipping Paper Entry, 47 GSI CR: A. Placarding Applicability, 55 2. Small Quantity Exception- Section 173.4 of 49 CFR provides substantial exceptions for very small quantities of most Hazard Materials. The regulatory relief provided is extensive and covers the areas ofpackaging, marking, labeling, shipping papers, and Placarding providing the shipment meets all the conditions contained within that Section. Three General conditions which must be met in all cases are: 1. The MAXIMUM quantity of material that may be shipped in EACH inner container is limited to the following for: Liquids other than Division 6.1, Packing Group 1-30 ml (1 ounce) Solids other than Division 6.1, Packing Group 1-30 g (1 ounce) Division 6.1, Packing Group 1-1 g (.04 ounces) 2. The Gross Weight of the completed "package" can not exceed 29 kg (64 pounds). "Gross Weight" is the material PLUS the packaging. 3. The outside of EACH package must be marked with the words: "This package conforms to conditions and limitations specified in 49 CFR 173.4" 4. It should be stressed that the above are just three (3) ofthe conditions. Section 173.4 contains other conditions relative to packaging, cushioning materials, drop tests etc. Anyone desiring to use the exceptions contained in 173.4 should check that Section for compliance with all applicable conditions. 3. Other Exceptions- There are other exceptions contained in the regulations which may or may not be applicable to particular shipments. Examples and 49 CFR references are: Agricultural Operations- (173.5) Consumer Commodities- (171.8 plus "Consumer Commodities" authorization in Exception Authori zation Section to which referred by Column (8A) for the material being reclassified.) Hazardous Wastes: Lab Packs- (173.12(b)) Open head drum- (173.12(a)) Reuse of Packagings- (173.12(c)) Salvage Drums- (173.3(c)) Modal Exceptions in Parts 174-177 as appropriate. 32 (0691) 1991 GSI Cotqwter Services Inc., Branson, MO 65616 Reprinted with |wnnifm All rights reserved ABD00130710 G5I Computer Services, Inc.___________ P.O. Box 1926 Branson, MO 65616 Telephone: (417)334-7071 Fax: (417)334-3874 OWNER REGISTRATION FORM We know that you will find GSI's "A, B, C's of the Transportation of Hazardous Materials" to be a valuable reference tool. In an effort to keep it current GSI Computer Services Inc. will be publishing an "A, B, C's of the Transportation ofHazardous Materials Update Letter". This letter will be edited by the author of the "A, B, C's of the Transportation of Hazardous Materials", Mr. Gary J. Groman, will contain changes and updates to your edition ofthe book and timely information on regulatory changes. It will be provided FREE to Registered Owners of the "A, B, C's of the Transportation of Hazardous Materials". To become a Registered Owner, the Registration Form furnished below must be returned to the above address within 30 days. OWNER REGISTRATION FORM Company Name Division Mail Stop Name First Last Middle Initial .Street Address or Post Office Box rCity Telephone Number ( } State Zip Date Product Was Acauired // Product Obtained From (Please Circle As Appropriate) GSI Class Labelmaster Direct Purchase GSI Other Please Furnish Information on the following: GSI In House Training Programs (Conducted by GSI staff) _____ Basic Transportation of Hazardous Materials Course (Pre HM-181) _____ Basic Transportation of Hazardous Materials Course (HM-181) _____ Basic transportation of Hazardous Wastes Course _____ Basic Air Transportation of Dangerous Goods Course _____ Ultimate Demo For TERIMS (Transportation Emergency Response Information Management System ABD00130711 RESERVED- Intentionally left blank. Please turn to page 35. 33 (0691) O 1991 GSI Congruto Soviets Inc., Brinson, MO 65616 Reprinted vitb peimraioa. All rights reserved. ABD00130712 RESERVED- Intentionally left blank. Please turn to page 35. 34 (0691) O 1991 GSI Congxiter Services lac., Branson, MO 65616 Reprinted with permission. All rights reserved. ABD00130713 THEA.B.C'sOFMARKING A. Proper Shipping Name- The Proper Shipping Name from Column (2) of the 172.101 Table must be marked on the outside of EACH package or overpack as illustrated by the Acetone marking in Figure 35A (172.301(a)). The Proper Shipping Name is the most appropriate name for the Hazardous Material appearing in Column (2) of the 172.101 Table in Roman Type. GSI CR: A, Proper Shipping Name Determination, 11; A. Shipping Paper, 45 Hazardous Wastes: If the Proper Shipping Name in Column (2) of the 172.101 Table for a Hazardous Waste does not contain the word Waste it must be added preceding the Proper Shipping Name appearing in Column (2) and marked on the package or overpack in a manner similar to the Waste Flammable liquids, n.o.s. marking in Figure 36A on Page 36. If the Proper Shipping Name shown in Column (2) of the 172.101 Table for a Hazardous Waste does contain the word Waste as it does for the Proper Shipping Names Hazardous waste liquids, n.o.s. and Hazardous waste solid, n.o.s., the word Waste must be left exactly where it appears and the Proper Shipping Name marked on the package or overpack must be exactly as listed in Column 2 of the 172.101 Table (172.101(c)(9)). GSI CR: A. & E. Hazardous Waste Definition, 21 B. Technical Name Rule- If the Proper Shipping Name marked on the package is one of the names listed in 172.203(k)(3), the Technical Name or Names required by 172.203(k) must be marked on the surface of the package in parentheses in association with the Proper Shipping Name (172.301(b)). The (Ethyl ether, Xylene) markings following the Proper Shipping Name Waste Flammable liquids, n.o.s. in Figure 36A on page 36 illustrates how this marking should be made. GSI CR: A. Technical Name Rule, 15; B. Shipping Paper, 45 C. Identification (TJN/NA) Number- The Identification (UN or NA) Number including the UN or NA prefix shown in Column (4) ofthe 172.101 Table must be marked on the outside of EACH package or overpack in association with the marked Proper Shipping Name as illustrated by the UN 1090 marking in Figure (172.301(f)(1)), this writer recommends that it always be marked on the package so that it is not left off when the exception does not apply. GSI CR: E. Column (4) Identification (UN or NA) Number, 2; D. Shipping Paper, 46 D. Name & Address- The name and address of EITHER the Consignee or the Consignor should also be marked on the package as illustrated for a box in Figure 35A and for a drum in Figure 36A on page 36 (172.301(d)). Although there are exceptions contained in 172.301(d)(l)-(2) your author recommends 35 (0691) O 1991 GSI Computer Services lac., Branson, MO 65616 Reprinted with permaaioo. All rights reserved. ABD00130714 that the Name and Address of BOTH the Consignee and Consignor be marked on the package. This will enhance the likelihood of the package getting to the consignee, eliminate the potential for omission when required, and facilitate the standardization of the marking process for all shipments. 1. Hazardous Wastes: For packages ofHazardous Wastes this requirement is normally met by complying with the provisions of 40 CFR 262.32(b) which requires each package of Hazardous Wastes having a capacity of 110 gallons or less to be marked with the following warning and information: HAZARDOUS WASTE- Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency. Generator's Name and Address Manifest Document Number Packages of Hazardous Wastes marked as above will meet the requirement of both 172.306 and 40 CFR 262.32(b). It should be noted that there is no required format or U.S DOT or EPA label that must be used to meet these requirements. These markings are illustrated in Figure 36A. Waste Flammable liquids, n.o.s. (Ethyl ether. Xylene) UN 1993 (F003) RQ E. Orientation Markings- Any combir nation package containing a Haz ardous Material in liquid form should have any inside packaging contain ing liquid Hazardous Materials packed in the outside packaging with their closures upward. In addition HAZAiUXDUSWASTE-FederalLaw'ProJiJMB IniproperDisposal Iffoundconiacttbenearest police orpublie safety authorityortheU.S. EnvTOHnmtalProtediooAgQicy. Generator's Name and Address: the outside of the package should be marked with the orientation mark ings as specified in ISO Standard Generate Inc., 2 Dirt St. Fly, CA Manifest Document Number: CA122131415189001 R780-1968 on two (2) opposite ver tical sides. The arrows must point upward so as to indicate the orienta tion of the inside containers) as il FIGURE 36A lustrated in Figure 35A on Page 35 (172.312(a)). Although this marie is not required to be marked on packages containing solids, it is not a violation to do so and your author would encourage that it be done. GSI CR: A, Combination Packaging, 25 There are some exceptions to the Orientation Marking requirement contained in paragraph 172.312(c) for certain types of shipments. GSI STRONGLY recommends that all combination packages containing liquid Hazardous Materials being offered for transportation under 49 CFR be automatically marked with the Orientation Arrows so as to indicate the orientation of the inside container. This will ensure regulatory compliance, increase the ease of training, and enhance safety by helping to keep the Hazardous Material in the package from leaking because the orientation ofthe package is not maintained. It's cheap insurance. Except for indicating the proper package orientation, arrows may not be placed on packages containing liquid Hazardous Materials (172.312(b)). 36 (0691) O 199] GSI Computer Service* Inc., Branson, MO 65616 Reprinted widi pennosion. All rights reserved. ABD00130715 F. Hazardous Substances- Each non bulk package of Hazardous Materials containing a Hazardous Substance as defined in 49 CFR must be marked with: 1. The letters RQ in association with the marked Proper Shipping Name (172.324(b)). The RQ marking is not part of the Proper Shipping Name. It is added in association with the Proper Shipping Name. Although 49 CFR is not specific as to where the RQ must be marked your author recommends marking the RQ on the package in a way similar to that illustrated in Figures 36A and 37A. GSI CR: C. Definition of, 17; C. Shipping Paper Entry, 48 2. If the Proper Shipping Name DOES NOT contain the name of the substance from the Appendix to 172.101 causing it to be regulated as a Hazardous Sub stance, the name of the substance as listed in the Appendix to 172.101 must be marked on the package or overpack, (in parentheses), in association with the Proper Shipping Name (172.324(a)(1)). The (Cupric acetate) markings in Figure 37A illustrate this marking. GSI CR: C. Definition of, 17; C. Shipping Paper Entry, 48 a. Hazardous Waste- If the Hazardous Substance being shipped is also a Hazardous Waste, one of the following, as appropriate and in parenthesis, may be substituted for the name listed in the Appendix (172.324(a)(2)-(3)): GSI CR: F. Shipping Papers, 49 (1). F or K Wastes- The EPA F or K Waste Number as illustrated in Figure 36A on Page 36. (2). Characteristic Hazardous Wastes-The D Num ber ql the entry EPA followed by the appropriate characteristic ignitability, corrosivity, reactiv ity, or toxicity. G. Packaging Specification Marks- If specification packaging is required the appropriate Specification Markings should be marked on the required outside packaging of the package as illustrated in Figure 35A and 36A. This is normally part ofthe "production process" and will already be marked on the packaging. It is mentioned here as a cross check. GSI CR: UN Specification Marking, Appendix 1. Page 11 H. Poisonous Hazardous Materials 1. Inhalation Hazard (Non Bulk Packaging)- Any non bulk package containing Division 2.3 materials or Division 6.1 Packing Group I liquids which_are_ poisonous by inhala tion under the criteria specified in 173.133(a)(2) shall be marked with the words Inhalation Hazard in association with the required labels (172.313(a)). GSI CR: E. Shipping Paper Entry, 48; Placarding, 172.505 a. Inhalation Hazard (Bulk Packaging)- Any bulk package containing Division 2.3 materials or Division 6.1 Packing Group I liquids which are poisonous by inhalation under the criteria specified in 173.133(a)(2) shall be marked with the words Inhalation Hazard in association with the required placards on at least two (2) sides (172.313(a)). 2. POISON- Each non bulk plastic outer packaging used as a single or composite packaging for Division 6.1 materials must be permanently marked with the word POISON in letters at least 6.3 mm (.25 inches) high within 150 mm (6 inches) of the closure (172.313(b)). I. Exemption Packaging- If the package being marked is authorized by an Exemption the outside of the package must be marked DOT-E followed by the number assigned (172.301(c)). i.e. DOT-E 1234. GSI CR: A. Shipping Paper Entry, 47 37 (0691) 1991 GSI Cotuxaer Services Inc., Branson, M0 6S616 Reprinted with pemussion. All rights reserved. ABD00130716 J. Radioactive Materials fRAMV In addition to any other required markings, the following marks must be considered and marked as applicable if the package contains a regulated Radioactive Material: a. USA in conjunction with the package specification marking IF the Radioactive materials are destined to be exported (172.310(a)(3)). b. Marked TYPE A or TYPE B as appropriate (172.310(a)(2)). c. The Gross weight (mass) if more than 110 pounds (50 kg) (172.310(a)(1)). K. Overpack- Overpacks of Specification Packagings must be marked with an indication that the overpacked packages inside comply with prescribed specifications unless the Specification Markings on the over packed packages are visible from the outside of the Overpack (173.25(a)(4)). The Marks and Labels on each of the packages overpacked be reproduced on the outside of the overpack unless the Marks and Labels on the oveipacked packages are visible from the outside of the Overpack (173.25(a)(2)). An Overpack is an enclosure that is used to provide protection or convenience in the handling of a package or to consolidate two or more packages (171.8). Packages containing Class 8 or Division 5.1 materials in Packing Group I may not be overpacked with any other material (173.25(a)(5)). GSI CR: C. Overpack Definition & Illustration, 26 L. ORM-D Designation- In addition to any other marking requirements, ifColumn (3) ofthe 172.101 Table shows the Hazard Class as an ORM-D, each package must also be marked with the appropriate ORM-D Designation (172.316(a)). This marking is illustrated in Figure 38A and should be marked on the package as follows: ORM-D 1. Use ORM-D for all modes but air. 2. Use ORM-D -AIR for shipments prepared and packaged for air under 173.27. 3. Be marked on an end or side of the package immediately following or below the Proper Shipping Name inside a rectangle that is approxi mately 6.3mm (1/4") larger on each side than the Designation itself. ORM-D-AIR M. Class 1 EX #- Unless excepted by paragraphs 172.320(bl-172.320fdl each package of Class 1 (Explosives) must be marked with the EX-number for each substance, article or device contained within it (172.320(a)). FIGURE 38A N. Prohibited Marking- No person may mark a package with the Proper Shipping Name or Identification Number of a Hazardous Material unless the package contains the identified Hazardous Materials. GSI CR: D. Prohibited Labeling, 42; G. Prohibited Shipping Paper Entries, 45; B. Placarding, 55 O. Marking Specifications 1. Non Bulk- All the markings required to be marked on the outside ofthe package by Subpart D of Part 172 of49 CFR must be printed on the surface ofthe package on a background ofa sharply contrasting color, be durable, in English, and unobscured by labels, attachments or anything else that could substantially reduce their effectiveness (172.304(a)). GSI CR: UN Package Specification Markings, Appendix I, Page 11 2. Bulk Packagings- The general marking requirements and specifications for bulk packagings are contained in 172.302. In addition the specific marking requirements will be found in 172.326 for Portable Tanks, 172.328 for Cargo Tanks, 172.330 for Tank Cars and multi-unit tank car tanks, and 172.332 for any other bulk packaging. 38 (0691) O 1991 GSI Coojwter Services Inc., Branson, MO 6S6K Reprinted with pmiri All rigba reserved. ABD00130717 THE A. B. C*s OFLABELING Difference Between "Marking" & "Labeling** The question is often asked "What is the difference between marking and labeling?". Generally they both do the same thing, communicate information about the material in the package or its handling. The difference, then, is not in WHAT they do but in HOW they do it. The regulations pertaining to marking are not very specific as to their size, color, or shape (172.304). On the other hand the regulations pertaining to the labeling required by Subpart E of Part 172 are very specific as to size, color, and shape (172.407). GSI CR: DOT Labeling Chart With Colored Pictures, Appendix IV A. 172.101 Table Label (Column (611 - Unless excepted each package or containment device must be labeled with the label or labels specified in Column (6) of the 172.101 Table (172.400(a)). To select the proper 172.101 Table Label find the Proper Shipping Name entry in Column (2) of the 172.101 Table. Once the Proper Shipping Name is found the label or labels will be found in Column (6) directly to the right of the Packing Group entry in Column (5). Labels representing the Primary Hazard, the Class shown in Column (3) for the entry, must have the Class Number-QMQr Division 5.1 or 5.2. the Division Number in the lower comer ofthe label (172.405(b)). For all Classes except Class 7 and 9 the use oftext indicating the hazard is optional i.e. CORROSIVE (172.405(a)). GSI CR: F. & G. Columns (5) & (6), 3 Hazardous Material Table - 172.101 Table Sym Hazardous materials descriptions and bol proper shipping names (1) (2) Hazard Identifi- Pack class or cation ing Division Numbers group (3) (4) (5) Label(s) Required (If not excepted) (6) Acetone D Dichlorobutene 3 8 Bipyridilium pesticides, liquid, toxic, n.o.s. 6.1 Flammable liquids, corrosive, n.o.s. 3 Illustrations: FIGURE 39A UN1090 n NA2920 i UN3016 i n HI UN2924 i FLAMMABLE LIQUID CORROSIVE, FLAMMABLE LIQUID POISON POISON KEEPAWAY FROM FOOD FLAMMABLE LIQUID, CORROSIVE 1. Reference to Columns (5) and (6) of the 172.101 Table or Figure 39A for the Proper Shipping Name Acetone indicates that the label to be applied to each package of Acetone is the FLAMMABLE LIQUID label. Figure 40A on page 40 illustrates the proper application of this label. 2. If Column (6) shows more than one label for the Proper Shipping Name and Packing Group, all labels shown for that Proper Shipping Name and applicable Packing Group must be affixed. Reference to Columns (5) and (6) of the 172.101 Table or Figure 39A for the Proper Shipping Name Flammable liquids, corrosive, n.o.s. indicate that two (2) different labels, the FLAMMABLE LIQUID label and CORROSIVE label, must be applied to each package. Both labels must be applied as required by 172.406. 3. The label or labels selected from Column (6) must be appropriate for the Proper Shipping Name of the material and the Packing Group of the material as shown in Column (5). Reference to Columns 39 (0691) O 1991 GSI Computer Services Inc., Branson. MO 65616 Reprinted with peranssion. All rights rescued. ABD00130718 (5) and (6) of the 172.101 Table or Figure 39A for the Proper Shipping Name Bipyridilium pesticides, liquid, toxic, n.o.s. indicates that the label to be applied to each package ofBipyridilium pesticides, liquid, toxic, n.o.s. having a Packing Group of I or II is the POISON label but that the KEEP AWAY FROM FOODS label must be used if the Packing Group is III. Acetone XJN1090 THIS END UP From: Mr. Kleen Inc. 4 Solvent Drive Notspent,. MO OOOOo-ww To: Purify Inc. 2 Besure Lane Cleansville, PA 00000-0000 FIGURE 40A GSI IPOT-12B65 I 4G/X30/S/91 USA/+GS0001 B. Subsidiary Risk (Hazard! Labeling- As a general rule each Hazardous Material will be classed under ONE DOT Hazard Class. This will generally be the Hazard Class appearing in Column (3) ofthe 172.101 Table, required to be entered as part of the Basic Description on the Shipping Paper, and used to select the initial Labels. Some materials however meet the definition of more than one Hazard Class. The hazard or hazards not identified by the Primary Hazard are called Subsidiary Hazards (Risks). Subsidiary Hazard labels may_not_haye_?he_Class_or Division number displayed on them (172.405(b)). 1. Subsidiary Risk Labeling of Materials Specifically Listed in the 172.101 Table- Generally the Subsidiary Risk ofmaterial specifically listed in the 172.101 Table can be determined by comparing the Primary Hazard Class shown in Column (3) to the Labeling in Column (6). Generally if more than one (1) label is listed, the first label listed represents the Primary Hazard and the second and subsequent label(s) represent the Subsidiary Hazard(s) (172.101 (g)). GSI CR: G. Column (6)-Labels, 3 Illustration: Reference to the Dichlorobutene entry in the 172.101 Table or Figure 39A on page 39 indicates, in Column (3), thatthe Primary Hazard is Class 8. Column (6), for that entry, shows that both a CORROSIVE and FLAMMABLE LIQUID label must be used. The CORRO SIVE label, the first label listed, covers the Primary Hazard and the FLAMMABLE LIQUID label, the second label listed, with the 3 removed, would cover the Subsidiary Risk. 2. Other Subsidiary Risks Labeling- Other than Class 2 materials, each package containing a material meeting the definition of more than one (1) Hazard Class must be labeled with Subsidiary Hazard labels in accordance with the Subsidiary Hazard Labels Table in 172.402(a). This table is illustrated in Figure 41A on page 41. This requirement applies to all materials meeting the definition ofmore than one Hazard Class even to a material specifically identified in the 172.101 Table if Column (6) does not contain the Subsidiary Risk. Illustration: A mixture having a primary Hazard Class of 3, a Subsidiary Hazard of Class 8, and a Packing Group of II would have to be labeled with the FLAMMABLE LIQUID label for the Primary Hazard Class 3. In addition, a comparison ofthe Subsidiary Hazard and its Packing 40 (0691) O 1991 GSI Computer Service* toe., Branson, MO 6561$ Reprinted with pcnmssion. All rights reserved. ABD00130719 Group to the Subsidiary Hazard Column for 8 and Packing Group II Row in the Subsidiary Hazards Labels Table in 172.402(a) or Figure 41A shows an X where they intersect. A CORROSIVE label would also be required to show the Subsidiary Hazard even if not shown in Column (6) ofthe 172.101 Table. The CORROSIVE label must have the8 removed because it is a Subsidiary Hazard label. The Primary and Subsidiary Hazard labeling for this example is shown in Figure 41B. Subsidiary hazard level (Packing Group) I................ n.............. m............. SUBSIDIARY HAZARD LABELS Subsidiary Hazard (Class or Division) 3 4.1 4.2 4.3 5.1 6.1 X kith *** X X X X X XXX X * N XXN N 8 X X- Required for all modes. N- None Required. * Required for vessel only **- Required for aircraft and/or vessel. ***- Impossible as Subsidiary Hazard FIGURE 41A C. Label Placement- When labeling is required they must be affixed to a surface ofthe package or containment device, other than the bottom, on the same surface as the marked Proper Shipping Name ifthe dimensions ofthe package or containment device is adequate (172.406(a). When Primary and Subsidiary Hazard labels are requiredthey must be displayed next to each other (within 150 mm (6 inches) ofone another) (172.406(c)). 1. Placement Exceptions* Labels may be printed on or placed on a securely affixed tag or affixed by any other suitable means to cylinders; packages with irregular surfaces to which labels cannot be satisfactorily affixed; and to packages containing no Class 7 (Radioactive Materials) with dimensions less than those ofthe required label (172.406(b)). Illustrations: Figure 40A illustrates the placement of a single label and Figure 41B illustrates the application of Primary and Subsidiary Risk labels. THIS END UP Flammable liquids, corrosive, n.o.s. (Methanol, Potassium hydroxide) UN2924 Fr: Mr. Kleen Inc. 4 Solvent Drive Notspent,. MO 00000 To: Purify Inc. 2 Besure Lane Cleansville, PA 00000 FIGURE 41B GSI |POT-12B65 4G/X30/S/91 USA/+GS0001 41 (0691) C 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with penmssioo. All rights reserved. ABDOO130720 D. Prohibited Labeling- Labels requiredby Subpart E ofPait 172 must not be put on packages that do not contain Hazardous Material or do not represent a hazard ofthe Hazardous Material in the package (172.401(a)). No mark or other media may be placed on a package that could by its color, design, or shape be confused with any label prescribed in Subpart E of Part 172 (172.401(b)). These prohibitions do not apply to packages labeled in accordance with the UN Recommendations, the IMDG Code, the ICAO Technical Instructions or the Canadian TDG Regulations (172.401(c)). GSI CR: N. Marking, 38; G. Shipping Paper Entries, 45; B. Placarding, 55 E. Other Labels 1. Cargo Aircraft Only label- If the package or overpack contains either a Hazardous Material or Dangerous Good that can be transported ONLY on Cargo Aircraft, a CARGO AIRCRAFT ONLY (DANGER) label must be affixed to the surface of the package or overpack adjacent to the Hazard Class label (172.402(b)). 2. Radioactive Materials (Class 71- Packages containing Class 7 (Radioactive Materials) requiring labels must be labeled in accordance with 172.403(a) with two (2) ofthe right "Category" Labels and have the Name of the radionuclide, activity, and Transport Index, as appropriate entered in the corresponding space on the label (172.403(g)). a. RadioactiYe_Materials_(Class_7X:with_Subsidiary Hazard- Each package containing a Class 7 (Radioactive Material) that also meets the definition of one or more additional Hazard Classes must be labeled as a Class 7 as required bv 172.403 and for each additional hazard (172.402(c)). 3. Empty Label- There is no required use of the "Empty" label but it can be used to cover up existing marks and labels on "empty packages" that last contained Hazardous Materials (173.29(b)(1)). This label will probably most often be used on "Empty" packages of Class 7 (Radioactive Materials)( 173.427(d)). 42 (0691) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with penmssion. All rights reserved. ABDOO130721 THE A, B, C's OF SHIPPING PAPERS Introduction A. Biggest Source of Violation Activity and Shipment Delay- It has been this author's personal experience that the vast majority of violation activity and shipment delay is caused by Shipping Papers not prepared in accordance with 49 CFR (or other applicable regulations). Any Inspector, State Trooper, Enforce ment Person, or Carrier Acceptance Person, worth their salt will start their inspection with the Shipping Paper. Obviously if everyone looks at it and it is not correct, problems will result. This writer recommends as strongly as he can that emphasis be placed on ensuring that the Shipping Papers are correct. This will help Emergency Response Personnel respond effectively to accidents or incidents involving the shipment, eliminate potential enforcement activity, and limit potential customer problems that result when a shipment is delayed. B. Use Bv Emergency Response Personnel- Once the shipment leaves the Shipper's facility and enters the transportation system it is subject to those "conditions normally incident to transportation" as well as those that are not "normally incident" to transportation such as vehicle accidents, punctured drums, etc. In the event of an accident or incident involving the shipment, Emergency Response Personnel will have to make IMMEDIATE decisions as to how to handle it. The Shipping Paper provides VITAL INFORMA- TION needed to make these decisions such as, but not limited, to the Proper Ship(ID) Number and the amount of \. .\ ping Name, Hazard Class, the Identification material involved. The Identification (UN/NA) Numa required entry on the Shipping sponse Guidebook". This Guide- 'EMFRGiNCY \y RESPONSE XcUIDEBOOKy^f , \ ber from Column (4) of the 172.101 Table is Paper. It is keyed to the "Emergency Re book gives Emergency Response personnel information relative to the Hazmended responses, and other ac- MlttKt ards associated with the material, recomtions such as evacuation etc. Obviously if the UN or NA Number is not on the Shipping Paper or otherwise visible Emer- gency Responders will not have the benefit of this quick cross reference. Lives could hang in the balance. GSI CR: Appendix II- Introduction to Emergency Response Information Under Subpart G of 49 CFR C. Definition of "DOT 49 CFR" Shipping Paper- The U.S. DOT defines the term "Shipping Paper" as a "shipping order, bill of lading, manifest, or other document serving a similar purpose" that contains certain information (171.8). To be in compliance with 49 CFR, whatever "form" is used as the Shipping Paper, MUST contain the information REQUIRED by: 172.202 containing the Basic Description requirements consisting of: 1. Proper Shipping Name (172.202(a)(1)). 2. Hazard Class (172.202(a)(2)). 3. Identification Number (UN/NA) Number (172.202(a)(3)). 4. Packing Group, if any, preceded by the letters PG (172.202(a)(4)). 5. 1-4 above in sequence (172.202(b)). 6. Quantity of Material (172.202(a)(5)). 172.203 containing Additional Description requirements which MAY apply to a particular Basic Description. 172.204 containing the Certification and Signature requirements. Although not part ofthe definition it should be noted that 172.201 (d) requires the inclusion ofthe Emergency Response Telephone Number required by 172.604. 43 (0691) O 1991GSI Computer Services Inc., Branson, MO 63616 Reprinted with permtuioo. Ail rights reserved. ABDOO130722 D. "U.S. DOT "vs "Normal" Shipping Paper- The term "Shipping Paper" as normally used within the transportation system means the piece of paper or documentation used for piece count, billing, accountability and other purposes involved with the day to day transportation of Hazardous as well as non hazardous materials. As used in 49 CFR the term "Shipping Paper" means documentation containing the specific Hazardous Materials information required by 49 CFR. 49 CFR does not require the use ofany specific form as the "DOT Shipping Paper". The system is flexible enough to permit the use ofANY form so long as the required 49 CFR information is on the form (171.8). As a practical matter by Highway it is very common to see the normal "Straight Bill ofLading" used for shipments of both hazardous and non hazardous goods. On the other hand, although not required by 49 CFR, the air industry requires the use of a particular Document called the SHIPPER'S DECLARA TION FOR DANGEROUS GOODS and those that ship Hazardous Wastes commonly use the Uniform Hazardous Waste Manifest. As long as the information required by DOT is present on whatever form is used the DOT Shipping Paper requirements have been met. E. General Applicability- As a general rule if a Hazardous Material is offered for transportation the person offering it MUST describe the material on a Shipping Paper in the manner required by Subpart C of Part 172 (172.200(a)). 1. Exceptions- Except for Hazardous Wastes and Substances, "DOT Shipping Papers" ARE NOT normally required for shipments of materials (172.200(b)): a. Identified by the letter A or Win Column (l)ofthe 172.101 Table except when offered or intended for transportation bv the mode indicated. A for Air and/or W for Water. GSI CR: B. Column (1) Symbols, 1 b. \That are ORM-D's except when offered or intended for transportation by air. (172.200(b)) Straight Bill No. Of Units KM DESCRIPTION AND CLASSIFICATION & Type (Proper Shipping Name, Hazard Class, UN/NA Number, PG) 1 Box Grandmas Kites 1 Box X Acetone, 3, UN1090, PG II lDrum X Flammable liquids, n.o.s. (Ethylcyclohexane) 3, UN1993, PG m 1 Box X Flammable liquids, corrosive, n.o.s. 3, UN 2924, PGB (Methanol, Potassium hydroxide) EMERGENCYCONTACT: 800-424-9300 FIGURE 44A Net Quantity (Wt/Vol) 45 kg 4L Total Quantity (Wt/Vol) 48 kg dkg 220 L 220 kg 25 kg 29 kg F. General Shipping Paper Description Requirements- All required shipping descriptions must: 1. Printing- It must be printed (manually or mechanically), in English, and in a legible manner (172.201(a)(2)). 2. Codes and Abbreviations- It may contain no codes or abbreviations except as authorized or required by 49 CFR (172.201(a)(3)). 3. Multiple Page Shipping Papers- A Shipping Paper may consist of more than one page provided each page is numbered consecutively AND the First Page bears a notation specifying the total number of pages included in the Shipping Paper i.e. Page 1 of 3 Pages (172.201(c)). 44 (0691) O 1991 GSI ConpuKr Service* Inc., Branson, MO 6S616 Reprinted with permission. All rights reserved. ABDOO130723 4. Hazardous Materials with NON Hazardous Materials On The Same Shipping Paper- When a Hazardous Material is shown on the same shipping papers with a nnn hazardous material the description of the HAZARDOUS MATERIAL must be: 1. Shown first (172.201(a)(l)(i)), or 2. Entered in an ink of a contrasting color. (172.201(a)(1)(H)). In this case the description can be located anywhere on the shipping paper and/or intermixed with the non hazardous material entries, or 3. Identified by the entry ofan X placed BEFORE the Proper Shipping Name in a Column captioned "HM" (172.20 l(a)(l)(iii)). If this option is used the Hazardous Materials may be placed anywhere on the Shipping Paper. Illustration- In Figure 44A the "Grandma's Kites", the first entry on the Shipping Paper, is not a Hazardous Material. It is described on a Shipping Paper with Hazardous Materials. They are listed first and not entered in an ink of a contrasting color so an X must be placed in the "HM Column" before the Proper Shipping Name for each of the Hazardous Material entries. Your author believes that, in most cases, the X option will be the most efficient of the three (3) choices. G. Prohibited Entries- A material not may not be described on a Shipping PaNumber (172.202(e)). meeting the definition of a Hazardous Material per using either a DOT Hazard Class or a UN/NA Illustration: A package of"Paint" hav- ing a Flash Point of over 250F described on a Shipping Paper as "Paint, Flammable liquid, UN1263", "Paint, Flammable liquid", or "Paint, UN1263". A recommendation would be to describe it as Paint. GSI CR: N. Marking, 38; D. Labeling, 42; B. Placarding, 55 THE A B C's OF THE BASIC DESCRIPTION (172.2021 To ensure compliance with 49 CFR all Shipping Papers, including Hazardous Waste Manifests, must contain a Basic Description containing the following information in sequence: A. Proper Shipping Name- The FIRST Item in the Basic Description Sequence is the Proper Shipping Name listed in Column (2) of the 172.101 Table for the Hazardous Material (172.202(a)(1)). The entries Acetone, Flammable liquids, n.o.s., and the Flammable liquids, corrosive, n.o.s. in Figure44A illustrate this entry. GSI CR: C. Column (2), 1; A. Proper Shipping Name Determination, 11; A. Marking, 35 B. Technical Name Rule- If the Proper Shipping Name is one of the names listed in 172.203(k)(3) the Technical Name or Names required by 172.203(k) must be entered in parentheses in association with the Basic Description. Although not a part of the Basic Description this writer has elected to discuss it here because of its close association with the Basic Description not only under 49 CFR but under international regulations such as ICAO and the IMDG Code. If only one material causes the material to be a Hazardous Material, its Technical Name must be listed in parentheses as illustrated in the Flammable liquids, n.o.s. (Ethyicyclohexane) entry in Figure 44A. If the Hazardous Material is a mixture or solution of two (2) or more Hazardous Materials the Technical Names of at least two (2) components most predominantly contributing to the hazards must be entered in parentheses (172.203(k)(2)). The Flammable liquids, corrosive, n.o.s. (Methanol, Potassium hydroxide) entry in Figure 44A illustrates this requirement. The location of either of the Technical Names in parentheses for either of these entries in Figure 44A is considered to be in "association with the Basic Description". 45 (0691) O 1991GSI Computer Soviets Inc., Branson, MO $$616 Reprinted with permmtoa. Ail rights reserved. ABDOO130724 The word "contains" may also be used in association with the Technical Name if appropriate (172.203(k)). Your author believes the use of the word "contains" would be appropriate in the case of a mixture or solution and not appropriate when describing commercially pure materials. Actual concentrations or concentration ranges are required for Organic Peroxides (Division 5.2) which may qualify for more than one generic description depending on the concentration (172.203(k)). GSI CR: A. Technical Name Rule, 15; B. Marking, 35 C. Hazard Class- The SECOND Item in the Basic Description Sequence must be the HAZARD CLASS listed in Column (3) of the 172.101Table for the Hazardous Material 3, 4.3, 6.1, 8 etc. (172.202(a)(2)). Straight Bill No-Of Units HM DESCRIPTION AND CLASSIFICATION Net Quantity &TVpe (Proper Shipping Name, Hazard Class, UN/NA Number,PG) (Wt/Vol) Total Qtantity (Wt/Vol) 2 Bxs 25 bxs X Aldrin, 6.1, NA2761, PG II, DOT-E1234, RQ X Butane, 2.1, UN1011, Ltd Qty FIGURE 46A 56 lbs 64 lbs 300 lbs 400 lbs All the Class or Division entries immediately after the Proper Shipping Names in Figures 44A and 46A illustrate the Hazard Class entry. Although some materials may meet the definition of more than one Hazard Class the entry to be entered, as illustrated by the Class 3 entry in the Flammable liquids, corrosive, n.o.s. description in Figure 44A, for a material with a Subsidiary Risk, must reflect the Primary Hazard . Although there is a permissive provision within 172.202(a)(2) that permits the addition of additional information such as the Subsidiary Hazard in parentheses after the required Hazard Class entry, it is this writer's opinion that it will tend to confuse the issue and result in a lack of standardization. GSI CR: D. Column (3), 2; Classification, 7; B. Subsidiary Risk Labeling, 40; E. Placarding, 56 D. Identification (UN/NA) Number- The THIRD Item in the Basic Description Sequence is the Identifi cation Number including the appropriate prefix, UN or NA, listed in Column(4) of the 172.101 Table for the entry (172.202(a)(3)). This entry is illustrated in all the Hazardous Materials descriptions in Figures 44A and 46A right after the Class or Division entries and contains either the prefix UN or NA. GSI CR: E. Column (4), 2; C. Identification (UN/NA) Number Marking, 35 E. Packing Group- The FOURTH Item in the Basic Description Sequence is the Packing Group listed for the material in Column (5) of the 172.101 Table preceded by the letters PG (172.202(a)(4)). The Packing Group is an upper Case Roman Numeral I, II, or III. All the Hazardous Materials descriptions in Figures 44A and 46A except for Butane in Figure 46A illustrate this entry. As illustrated by the Butane description in Figure 46A, no Packing Group is entered if none_appears in Column (51 of the 172.101 Table. GSI CR: F. Col. (5), 3; Packing Group Definition, 6; A.-B. Classification, 7; B. Select Packaging, 27 F. Required Sequence of Basic Description- The Proper Shipping Name, Hazard Class, Identification Number, and Packing Group MUST BE IN SEQUENCE with nothing between them except as permitted or required. The proper sequence for these entries is illustrated in the Hazardous Materials descriptions in Figures 44A and 46A (172.202(b)). The only thing this writer recommends even considering interspersing between them is the Technical Name in parentheses between the Proper Shipping Name and Hazard Class as permitted by 172.202(d). G. Quantity of Material- Except for empty packagings, compressed gas cylinders, and bulk packagings the "Total Quantity" of the material covered by the Basic Description , including the units of measurement, must be entered on the Shipping Paper (172.202(a)(5)). Although the regulatory standard for units of 46 (0691) O 1991 GSI Cocqwter Setvicea loc., Bnnsoo, MO 65616 Reprinted with penmnioo. All rights reserved. ABDOO130725 measurement is the International System ofUnits (SI or Metric) (171.6(a)) D.O.T. has publicly stated, through its HMIX Bulletin Board that either SI or U.S. Units of measurement mav be used. Both methods are illustrated in Figures 44A through 51 A. A list ofconversion values and abbreviations is contained in 171.6 and the Metric Conversion Chart in Appendix V. The TOTAL QUANTITY entry may: 1. Be given weight OR volume or as otherwise appropriate. 2. Appear either before OR after OR both before and after the Proper Shipping Name, Hazard Class and Identification Number information on the Shipping Paper and may be abbreviated (172.202(c)). 3. Be either the "net amount" of the material in the package or the "Gross Weight", the weight of the material in the package plus the packaging, as appropriate. Generally the "net" figure is used for air or Hazardous Waste shipments and the "Gross Weight" for Highway Shipments. Illustration: All the entries in the "Quantity" Columns of Figures 44A through 46A illustrate these entries. Authors note: Although the above is not currently in HM-181 it is in the 1990 Edition of49 CFR, has been for years, and will undoubtedly be put back in as HM-181 is rewritten over the next couple of years. Use of the "net quantity" will ensure compliance in either case. H. Emergency Response Telephone Number- A 24 hour Emergency Response Telephone number, including Area or International Access Code, must be listed on the Shipping Paper. It must be monitored at all'times the Hazardous Materials are in the transportation system and be the number of a person who has "comprehensive emergency response and accident mitigation informatio.n_fQL_that_material or has immediate access to a person who" has such knowledge (172.604(^1. The number must be entered immediately following the description of each Hazardous Material or entered once in a clearly visible location with an indication that it is for Emergency Response Information IF the number applies to each HaTarHnng Material entered on the Shipping Paper (172.604(a)(3)). The single number method is illustrated in Figure 44A. GSI CR: Appendix II- Introduction to Emergency Response Information Under Subpart G of 49 CFR ADDITIONAL DESCRIPTION REQUIREMENTS 072.2031 In any case where a Shipping Paper is required it will, at a minimum, contain a Basic Description. In addition, one OR more of the Additional Description requirements contained in Section 172.203 MAY or MAY NOT apply to a given Basic Description. Each paragraph in 172.203 represents a potential Additional Description Item that could be required. If one or more of the Additional Description Items specified in 172.203 applies to the Hazardous Material described in the Basic Description, the appropriate entries must be made. If none apply to the particular Basic Description then no Additional Description information has to be entered. This writer recommends that, EXCEPT where required to be placed elsewhere, the Additional Description information should be entered AFTER the Basic Description on the Shipping Paper. THE A. B. C's OF ADDITIONAL DESCRIPTION REQUIREMENTS (172.2031 A. DOT Exemptions- If the Basic Description describes a Hazardous Material being shipped under a DOT Exemption, the notation DOT-E followed by the "Exemption Number" assigned must be entered in association with the Basic Description (172.203(a)). A shipment being shipped under "DOT Exemption # 1234" must have the entry DOT-E 1234 entered on the Shipping Paper after the Basic Description as shown for the Aldrin entry in Figure 46A. B. Limited Quantity- Ifa material is offered for shipment as a "limited quantity" the words Limited Quantity or Ltd Qty must be entered on the Shipping Paper after the Basic Description (172.203(b)). This entry is illustrated by the entry Ltd Qty after the Butane description in Figure 46A. GSI CR: H. Limited Quantities, 31 47 (0691) 1991 GSI Congwter Service* Inc.. Branson, MO 65616 Reprinted with penmuiotL All rights reserved. ABDOO130726 C. Hazardous Substances i. m- At a minimum the letters RQ must be entered on the Shipping Paper either before or after the Basic Description IF the material covered by the Basic Description is regulated as a Hazardous Substance as shown in the Aldrin entry in Figure 48A (172.203(c)(2)). GSI CR: Hazardous Substances, 17; F. Marking, 37 2. Name, of Hazardous Substance- In addition, IF the name(s) of the constituent(s) causing it to be regulated as a Hazardous Substance, as listed in the Appendix to 172.101, is not part of the Proper Shipping Name it must be entered in parentheses in association with the Basic Description. The (nButyl phthalate) entry in the Environmentally hazardous substances, liquid, n.o.s. description in Figure 48A illustrates this entry (172.203(c)(1)). GSI CR: Hazardous Substances, 17; E. Marking, 37 Straight Bill No.Of Units HM DESCRIPTION AND CLASSIFICATION Net Quantity & Type (Proper Shipping Name, Hazard Class, UN/NA Number,PG) (Wt/Vol) 2Bxs X Aldrin, 6.1,NA2761, PG II, DOT-E1234, RQ 28 kg lODrms X Motor fuel anti-knock mixtures (Tetraethyl lead), 6.1, UN1649, PG I (Tetraethyl lead) RQ 500 L IBx X Environmentally hazardous substances, liquid, n.o.s., 9, UN3082, PG III (n-Butyl phthalate) RQ 15 kg IBx X Magnesium hydride, 4.3, UN2010, PG I Dangerous when wet FIGURE 48A 15 kg Total Quantity (Wt/Vol) 30 kg 2200 kg 18 kg 20 kg D. Dangerous When Wet- Ifthe package is required to be labeled with a DANGEROUS WHEN WET label the entry DANGEROUS WHEN WET must be entered on the Shipping Paper in association with the Basic Description (172.203(j)). As a general rule this entry will be required for all Division 4.3 Hazardous Materials. The DANGEROUS WHEN WET entry in the Magnesium hydride description in Figure 48A illustrates this entry. E. Poisons-Inhalation Hazard 1. Poison- IF the material meets the definition of a Division 6.1 (Poison) under 49 CFR and the fact that it is a Division 6.1 (Poison) is not disclosed by either the Proper Shipping Name, or the Hazard Class the word "Poison" must be entered on the SHIPPING PAPER in association with the Basic Description (172.203(m)(l)). Illustration- The Waste Allyl acetate entry in Figure 49A shows the Hazard Class as 3. AUyl acetate has a Subsidiary Hazard (Risk) of 6.1. There is no indication in either the Proper Shipping Name or Hazard Class entry that the material meets the definition of a Division 6.1. As illustrated by the Poison entry for the Waste Allyl acetate description in Figure 49A the word Poison must be added as an additional description item. 48 (0691) O 1991 GSI Computer Services Inc., Branson, MO 5616 Reprinted with permission. All rigbs reserved. ABDOO130727 2. Technical Name- If the Technical Name of the compound or principal constituent causing it to be regulated as a Division 6.1 (Poison) under Part 173 of 49 CFR is not part of the Proper Shipping Name, it must be added in parentheses as required by 172.203(k) (172.203(m)(2)). GSI CR: N.O.S. Technical Name Rule, 15; B. Shipping Paper Entry,-45 Illustration: The Motor fuel anti-knock mixtures description in Figure 48A is a Division 6.1 (Poison). The name of the constituent causing it to be regulated as a Division 6.1 (Poison) is Tetraethyl lead. It is not part of the Proper Shipping Name and must therefore be added in parentheses as required by 172.203(k). The (Tetraethyl lead) entry in the Motor fuel anti-knock mixtures description in Figure 48A illustrates this entry. 3. Poison-Inhalation Hazard-Hazard Zone- If the Basic Description covers a Division 2.3 (Poisonous Gas) or a Division 6.1, Packing Group I which is poisonous by inhalation under the criteria specified in 173.133(a)(2) the word Poison-Inhalation Hazard and the words Hazard Zone A, Hazard Zone B, Hazard Zone C, or Hazard Zone D, as appropriate must be entered. The word Poison does not have to be repeated if it is already part of the Shipping Description (172.203(m)(3)). GSI CR: H. Inhalation Hazard Marking, 37; E. Multiple Placarding, 56 UNIFORM HAZARDOUS WASTE MANIFEST l-Generatora US EPA ID No. Manifest Document No. 2. Page . 11. US DOT Description (Including Proper Shipping Name, Hazard Class, and ID No.) 12. Contail ex? No. Type 13. Total Quantity 14Unit Wl/Vol I WasteNo. a. Waste Allyl acetate, 3, UN2333, PGII, RQ (D001) Poison b. Hazardous waste solid, n.o.s., 9, NA3077, PG III RQ (EPA toxicity) 10 DM 1500 10 DM 4400 P P JJJ FIGURE 49A F. Hazardous Wastes- Shipments of Hazardous Wastes must be described on a specific form, the Uniform Hazardous Waste Manifest (EPA 8700-22), prepared in accordance with 40 CFR 262.20 (172.205(a)). The instructions for preparing this form for Blocks other than 11. are sufficiently explained in the Appendix to 40 CFR Part 262 and will not be explained in this text. In addition it is generally used as the DOT Shipping Paper under the permissive provisions of 172.205(h). Except as noted below, the description of a Hazardous Waste on the Manifest is the same as for any other Hazardous Material: 1. Waste in Proper Shipping Name- The word Waste must be added preceding the Proper Shipping Name if it is not part of the Proper Shipping Name appearing in Column (2) of the 172.101 Table as illustrated by the Waste Allyl Acetate entry in Figure 49A. If the word Waste is part ofthe Proper Shipping Name appearing in Column (2) of the 172. lOlTable, leave it where it is. The Hazardous waste solid, n.o.s. entry in Figure 49A illustrates this point. GSI CR: B. Hazardous Waste Proper Shipping Names, 12 49 (0691) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with pennmioo. All rights reserved. ABDOO130728 2. Quantity and Unit of Measurement Code- The Quantity ofMaterial covered by the Description must be entered in Column (Item) 13 on the Manifest. The Units of Measurement must be entered in Item 14 using the abbreviations specified_in_theJnstruction for Item 14 in the Appendix to Part 262 of 40 CFR which are illustrated below: G= Gallons P= Pounds T=Tons (2,000 lbs) Y= Cubic Yards L= Liters K= Kilogram M=Metric tons (1000 kg) N=Cubic Meters Illustration: All the entries for Items 13 and 14 in Figures 49A and 50A illustrate this entry. UNIFORM HAZARDOUS WASTE MANIFEST l.Gcnenton US EPA ID No. Manifest Document No. 2. Page 1 of 11. US DOT Deaaiptioa (lncfcrdmg Proper Shipping Name, Hazard Clan, and ID No.) 12. Co KtSlDCO 13. Total No. Type Quantity 14. Unit Wt/Vol i WasteNo. a. Waste Flammable liquid, n.o.s., (Acetone/Xylene), 3, UN1993 PG H (F003) RQ 1 Tr 16000 L FIGURE 50A |mm VMMm 3. Container Number and Type Code: Item 12 requires an entry for the "Number" (No.) and "Type" of containers being used to transport the Hazardous Waste. The entry for the "Type" of container must be as specified in the Instructions for Item 12 in the Appendix to Part 262 of 40 CFR. Some of the more commonly used packagings and their respective Container Codes are listed below: CF=Fiber or plastic boxes, cartons, cases DF=Fiberboard or plastic drums, banels, or kegs TC=Tank Cars CY=Cylinders DT=Dump Truck DM-Metal drums, barrels, kegs TP=Tank Portable TT=Cargo Tank (Tank Trucks) Illustrations: All the descriptions in Figures 49A and 50A illustrate this requirement. 4. Hazardous Substance- Name Exception- If the Hazardous Waste is also regulated as a Hazardous Substance and the Proper Shipping Name does not contain the name of the Hazardous Substance as listed in the Appendix to 172.101, one of the following, as appropriate and in parentheses, may be substituted for the name of the substance as listed in the 172.101 Appendix (172.203(c)(1)): GSI CR: D. Hazardous Substance Determination, 18 (a) . Waste Streams- If the Hazardous Waste being described is from an F or K Waste Stream the EPA F or K Waste Stream Number as illustrated in Figure 50A. (b) . Characteristic Hazardous Wastes - If the Hazardous Waste is a Characteristic Waste the corresponding D Number QR the entry EPA followed by the appropriate characteristic ignitability, corrosivity, reactivity, or toxicity as illustrated in Figure 49A on Page 49 may be entered in parentheses in lieu of the name of the substance listed in the Appendix to 172.101 (172.324(a)(2)-(3)). (1.) Separate_P._F^ and K Number Listings In Appendix to 172.101- There are separate EPA Hazardous Waste D, F, and K, Number listings in the 172.101 Appendix starting alter the Alphabetical listing of Hazardous Substances in List 1 of the Appendix. In making a Hazardous Substances determination for a package of Hazardous Wastes the "EPA Hazardous Waste Number" should be checked in the 172.101 Appendix. 50 (0691) O 1991 GSI Confute? Services Inc., Branson, MO 6S616 Reprimed with permission. All rights reserved. ABDOO130729 G. RESIDUE LAST CONTAINED (Almost Emptyl- Although permitted, except for any tank car containing any "Residue" of a Hazardous Material or packages containing a "Residue" of a Hazardous Substance, as defined in 171.8, there is no requirement that the entry RESIDUE: Last Contained be used in association with any Basic Description (172.203(e)(1)). The Basic Description for a Tank Car containing the residue of any Hazardous Material or any other package containing the residue of a Hazardous Substance must be prefaced with the entry RESIDUE: Last Contained (172.203(e)(2M3)). Illustration- The Description on a Tank Car containing a Residue of Acetone would be as illustrated in the Acetone entry in Figure 51 A. The letters RQ are not included because the Tank Car does not contain an RQ of a Material listed in the 172.101 Appendix. The RQ for Acetone is 2270 kg (5000 lbs). The Residue in the Tank Car is only 400 kg (800 lbs). The Residue ofSilver nitrate in the drum is 2 kg (4 lbs) which exceeds the .454 kg (1 lb) RQ for Silver nitrate. The Basic Description on the Shipping Paper must be prefaced with the words RESIDUE Last Contained as shown in Figure 51 A. Straight Bill No.Of Units & Type HM DESCRIPTION AND CLASSIFICATION Net Quantity (Proper Shipping Name, Hazard Class, UN/NA Number.PG) (Wt/Vol) Total Quantity (Wt/Vol) 1TC X RESIDUE Last Contained Acetone, 3, UNI090 PGB PLACARDED: Flammable Residue 400 L 1 Dm X RESIDUE Last Contained Silver nitrate, 5.1, UNI493, PG n RQ 2L Both the Tank Car and Drum are shown on 1 Shipping Paper for the purposes of illustration only. FIGURE 51A The Remainder of this Page and Page 52 intentionally left blank. Please go to Page 53. 51 (0691) O 1991GSI Computer Services Inc., Bnnsoo, MO $$616 Reprinted wizb penmnioo. All rights reserved. ABDOO130730 RESERVED- Intentionally left blank. Please turn to page 53. 52 (0691) O 1991 GSI Computer Service* Inc., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130731 THE Ar Br C's ofSHIPPING PAPER CERTIFICATION A. Shipper's Certification- The Certification must be on the Shipping Paper containing the Basic Description. The Shipper is certifying that the Hazardous materials described on the Shipping Paper have been properly classified, packaged, marked, labeled, documented, and are in full compliance with 49 CFR (172.204(a)). B. Signature- The Certification must be legibly signed by a principal, officer, partner, or employee of the shipper or his agent. It may be signed manually, by typewriter, or by other mechanical means. The person who signs the Certification is certifying, on BEHALF OF THE SHIPPER, that the shipment is in compliance with all applicable regulations. 1. Hazardous Waste Manifest- Item 16 of the Manifest contains the required certification. It must have the Printed or typed Name of the individual signing in the appropriate box, a manual signature in the appropriate box, and must be dated in the appropriate box. C. Form of the Certification- For highway and/or rail the Certification in 172.204(a)(l)should be used. This Certification, which is reproduced in Figure 53A, is commonly preprinted on Bills of Lading used for Highway and Rail transportation of Hazardous Materials and is the Certification preprinted on the Hazardous Waste Manifest in Item 16. CERTIFICATIONf172.204) This is to certify that the above named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation. (Signature) FIGURE 53A D. No Certification Required- Except for Hazardous Wastes no Certification is required for Hazardous Materials offered for transportation by motor vehicle AND transported in a cargo tank supplied by the carrier OR by the shipper as a private carrier unless the Hazardous Material is to be reshipped or transferred to another carrier (172.204(b)(1)). No certification is required for the shipment of an empty tank car by rail which previously contained a Hazardous Material and which has not been cleaned or purged (172.204(b)(2)). 53 (0691) O 1991GSI Computer Services Inc., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130732 THE A.B. Cs OF PLACARDING A. Placarding Selection (KIS Method!- Placards must be selected from the Tables provided in 172.504 which are illustrated in Figure 55A on page 55 (172.504(a)). To select the appropriate Placard using the KIS (Keep It Simple) Method do the following: 1. Select the Class or Division Placard from the 172.504 Tables a. Determine the Hazard Class or Division Number of the Hazardous Material. This can usually be determined from the Hazard Class portion of the Basic Description on the Shipping Paper or Column (3) of the 172.101 Table. GSI CR: C. Basic Description, page, 46 b. Refer to the top left hand comer of Table 1 in 172.504 m; for training purposes only, Figure 55A on Page 55. Go down the "Hazard Class or Division" (First) Column until the Hazard Class or Division Number of the Hazardous Material is found. If it's not found in Table 1 go to Table 2. c. Once the Hazard Class or Division Number is found in that Column go to the right to the "Placard Name" (Second) Column. The Placard Name in this Column of the entry is the name of the placard to be used. The "Placard Design Section Reference" (Third) Column contains a reference to the Section within Part 172 containing a black and white picture and specifics of the placard named in the "Placard Name" Column. Four (4) of the required placards must be used. d. Repeat a.-c. for each different Hazard Class or Division Number being shipped. 2. Multiple Placarding Requirements of172.505)- In addition to any placards required by the 172.504 Tables each transport vehicle, portable tank, freight container, or unit load device containing the following must be placarded as indicated: a. A Division 2.3 or 6.1 (Poisonous material) for which the Poison- Inhalation Hazard entry is required on the Shipping Paper by 172.203(m)(3) must be placarded with POISON or POISON GAS placards, as appropriate for the Division being placarded, on each side and end. This placarding is in addition to any other placards required by 172.504. If the placard required by 172.504 require a POISON or POISON GAS placard duplication is not required (172.505(a)). GSI CR: E. Inhalation Hazard on Shipping Paper, 48 b. A material that has a Subsidiary Hazard (Risk) of Division 4.3, Dangerous When Wet, as defined in 173.124 must be placarded with DANGEROUS WHEN WET placards on each side and end in addition to any other placards required by 172.504 (172.505(c)). c. 454 kg (1001 lbs) or more gross weight of fissile or low FIGURE 54A specific activity uranium hexafluoride must be placarded with RADIOACTIVE and CORRO SIVE placards on each side and end (172.505(b)). Illustration: The Hazard Class for Acetone is 3. The name ofthe placard in the Second Column ofthe Class 3 entry in Table 2 of 172.504 is FLAMMABLE. None ofthe mandatory Multiple Placarding requirements of 172.505 apply. Four (4) FLAMMABLE placards must be used. Figure 54A is a black and white illustration of this red and white placard. B. Placarding Exceptions- Thus far nice, easy, general placarding rules (KIS Method of Placarding). Get the Class or Division, select the appropriate placard(s) from the 172.504 Tables, check 172.505 for Multiple Placarding applicability, and make sure one (1) of each required placard is on each side and end 54 (0691) O 1991 GSI Computer Services Inc., Bnnsco, MO 65616 Reprinted with perawsion. All rights reserved. ABDOO130733 Category (Hazard Class/Division NumberAdditional description) Placard Name TABLE1 1.1.................................................................... 1.2.................................................................... 1.3.................................................................... 2.3..................................................................... 4.3..................................................................... 6.1 (PG I, Inhalation Hazard only).............. 7 (Radioactive Yellow III label only)........... EXPLOSIVES 1.1....:............................ EXPLOSIVES 1.2................................. EXPLOSIVES 1.3................................. POISON GAS........................................ DANGEROUS WHEN WET............. POISON................................................. RADIOACTIVE.................................. Design Reference 172.522 172.522 172.522 172.540 172.548 172.554 172.556 TABLE2 1.4..................................................................... 1.5..................................................................... 1.6..................................................................... 2.1.................................................................... 2.2.................................................................... 3........................................................................ Combustible Liquid........................................ 4.1......................1.................:........................... 4.2.................................................................... 5.1.................................................................... 5.2.................................................................... 6.1 (PG I-II No PG I Inhalation Hazard).... 6.1 (PG III).................................................... 6.2.1......... 1...................................................... 8........................................................................ 9........................................................................ ORM-D........................................................... EXPLOSIVES 1.4................................. EXPLOSIVES 1.5................................. EXPLOSIVES 1.6................................. FLAMMABLE GAS............................ NON-FLAMMABLE GAS................. FLAMMABLE..................................... COMBUSTIBLE.................................. FLAMMABLE SOLID....................... SPONTANEOUSLY COMBUSTIBLE OXIDIZER............................................ ORGANIC PEROXIDE..................... POISON................................................. KEEP AWAY FROM FOOD............. None....................................................... CORROSIVE....................................... CLASS 9................................................. None....................................................... 172.523 172.524 172.525 172.532 172.528 172.542 172.544 172.546 172.547 172.550 172.552 172.554 172.553 172.558 172.560 FIGURE 55A of whatever is being placarded. There are however, placarding exceptions that could apply. If the exceptions cause problems forget them and use the KIS Method. The worst thing that could happen using the KIS Method is that placards might be used that are not required. This is not a violation because of the Permissive Placarding provisions of 172.502(d) which specifically permits the display ofplacards when a Hazardous Material is being transported even though an excep tion could be used, providing the placarding otherwise meets the placarding requirements of 49 CFR. 1. The Table 2- 454 kg (1001 Pound) Exception- Placarding is not required for HIGHWAY and RAIL shipments of vehicles, rail cars, or freight containers containing: a. Less than 454 kg(l,001 lbs) aggregate (total) Gross Weight. OF b. Hazardous Materials listed in Table 2. Z/ FIGURE 55B 55 (0691) C 199] GSI CooputcT Services Inc., Branson, MO 65616 Reprinted with pcromiicn. AB rights reserved. ABDOO130734 Illustration: If a motor vehicle has 400 kg ( 882 lbs) gross weight (total weight of material plus packaging) of Class 8 materials and 400 kg ( 882 lbs) "gross weight'* of Class 3 Hazardous Materials for a total gross weight of 800 kg (1764 lbs) placarding would be applicable. The "aggregate" (total) gross weight of ALL the Hazardous Materials listed in Table 2 is not less than 454 kg (1,001 pounds). On the other hand, if the vehicle contained 200 kg (441 pounds )gross weight of EACH of these Table 2 materials placarding would not be mandatory. The total gross weight of Table 2 Hazardous Materials is 400 kg (882 lbs) which is less than 454 kg (1001 lbs) (172.504(c)). a. The 454 kg (1001 Pound) Exception Does Not Apply To- This exception does not apply to the following (172.504(c)) (1). Table 1 Hazardous Materials, or (2). Transport vehicles and freight containers required to be placarded under 172.505, or (3). Transportation by aircraft or vesselT or (4). Portable Tanks, Cargo Tanks, and Tank Cars 2. The Table 2- DANGEROUS Placard Exception- A DANGER OUS Placard mav be used in lieu of individual placards for freight containers, motor vehicles, rail cars, and unit load devices con taining two or more Hazard Classes or Divisions of Hazardous Materials requiring different Placards specified in Table 2. a. The_DANGEROUS Exception Does Not Apply- This exception does not apply to the following (172.504(b)): (1). Table 1 Hazardous Materials, or (2). When 2268 kg (5,000 pounds) or more of one Hazard Class or Division is loaded at one loading facility. Illustration- A motor vehicle containing 1362 kg (3,003 lbs) of Class 3 and 1362 kg (3,003 lbs) of a Division 6.1, Packing Group II Hazardous Materials may be placarded with either DANGEROUS placards or FLAMMABLE and POISON placards. If 3,000 kg (6607)pounds of Class 3 were loaded onto the truck at the next stop the truck must be placarded with FLAMMABLE Placards because 2,268 kg (5,000 lbs) or more of one Hazard Class or Division was loaded at one loading facility. In addition, the truck must be placarded with POISON placards to reflect the 1362 kg (3,003 lbs) of Division 6.1 materials also on board(172.504(b)). 3. Non Bulk Residue Exception- Non Bulk packagings containing only the residue ofTable 2 Hazardous Materials do not have to be included in determining placarding (172.504(d)). 4. Additional Exceptions- Additional Class, Division and Placard specific exceptions are authorized in 172.504(f)). 5. Applicability- Placarding applies to every shipment of Hazardous Materials except: a. Division 6.2 Infectious Substances b. ORM-D Materials c. Combustible liquids in Non Bulk Packagings 56 (0691) O 1991 GSI Conquer Soviet* tot, Brawn, MO 65616 Rcpraoed with pcnmnioa AH rigtus raaved ABDOO130735 d. Limited Quantities ofHazardous Materials when the words Ltd Qty or Limited Quantity appear on the Shipping Paper as required by 172.203(b). GSI CR: H. Ltd Qty Exception, 31; B. Ltd Qty Shipping Paper Entry, 47 e. Hazardous Materials packaged and offered for transportation under 173.4. GSI CR: H. Small Quantities, 32 C. Placarding Display- No person may transport a Hazardous Material in a motor vehicle or rail car unless the required placards are affixed IN THE PROPER MANNER. At a minimum, those having a placarding responsibility should ensure the following: 1. At least one of each of the required Placards is affixed to each END and SIDE of the motor vehicle or rail car (172.504(a)). A shipment of Division 4.3, Dangerous When Wet materials as defined in 173.124, must be placarded with four (4) DANGEROUS WHEN WET placards in a manner similar to that illustrated in Figure 57A. 2. The Placards are readily visible from the direction the motor vehicle faces except from the direction of another motor vehicle or rail car to which the placarded motor vehicle or rail car is attached (172.516(a)). 3. The Placards are secured so that the words or Identification Numbers (when authorized) are displayed horizontally reading from left to right (172.516(c)(5)). The DANGEROUS WHEN WET placarding in Figure 57A is in compliance with this provision. The FLAMMABLE placard in Figure 57 B is not. 4. The Placards are located at least 3 inches away from any marking or advertising. The 3 inches is a minimum. Keep the Placards a sufficient distance away from other marks and advertising so that the "effective ness" of the Placarding is not "substantially" reduced (172.516(c)(4)). The DANGEROUS WHEN WET Placard in Figure57A complies with this requirement. FIGURE 57B 5. The Placards are maintained by the Carrier in such a manner that their legibility, color, visibility, and format are not substantially reduced due to damage, deterioration, or obscurement by dirt or other matter (172.516(c)(6)). 6. The Placards are either affixed to a background of a contrasting color or have a dotted or solid line outer border which contrasts to the background color (172.516(c)(7)). 57 (0691) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with petmissioo. All rights reserved. ABDOO130736 D. Shipper Carrier Responsibility- Placarding applies to each person who offers a Hazardous Material for transportation OR who transports a Hazardous Material (172.500(a)). 1. Shipper- IF placarding is applicable to a particular shipment being offered for transportation the Shipper (person offering) MUST comply with the following: a. Highway Shipments- Provide (Offer) the placards unless the motor vehicle is already placarded (172.506(a)). The requirement is that the Shipper provide (offer) the placards. The best way for the Shipper to ensure that the vehicle is placarded is to "eye ball it". Although not required by 49 CFR this author recommends that, at a minimum, the shipper make a standard notation on the shipping paper similar to the following for every shipment: Placards offered by AcceptedRejected (Person offering puts initials in space after "by" and the appropriate response.) b. Rail Shipments- Affix the placards to the rail car (172.508(a)). The Shipper must also make the entry "Placarded" followed by the name of the placard on the Shipping Paper as required by 172.203(g)). It should be noted that placards displayed on transport containers, motor vehicles, or poitable tanks may be used to satisfy the rail placarding requirements IF the placards and method of display are in accordance with 49 CFR (172.508(a)) 2. Carriers By All Modes- Regardless of who has the responsibility to provide or affix placards "no person" may transport a Hazardous Material unless it is placarded as required by 49 CFR (172.500(a), 172.506(a)(1) for Highway Carriers, and 172.508(b) for Rail Carriers). E. What is to Be Placarded and Number of Placards- Unless excepted by 49 CFR each motor vehicle, bulk packaging, freight container, unit load device, or rail car containing any quantity of Hazardous Materials must be placarded on both sides and ends with the type ofplacards specified in Tables 1 and 2 of 172.504 and any other placards required (172.504(a)). Whenever placarding is required four (4) of each placard must be used. F. Prohibited Placarding 1. No Hazardous Materials or Wrong Placard- There is a specific prohibition against placarding a motor vehicle, freight container, unit load device, or portable tank that does not contain a Hazardous Material. Further, the placard MUST represent a hazard of the material being offered or transported (172.502(a)). To use a placard two conditions must be met: a. The motor vehicle, freight container, unit load device, portable tank or rail car must actually contain a Hazardous Material. AND b. The placard must represent a hazard of the material. It must be the right placard. GSI CR: N. Marking, 38; D. Labeling, 42; F. Shipping Paper Entries, 45 2. Signs or Devices Which_Could Be Confused With A Placard- Signs or other devices which may be confused with the required placards may not be affixed to motor vehicles, freight containers, portable tanks, or rail cars. Things that could cause confusion are items such as color, shape, design, or content. As a practical matter if you think you might have a problem in this area it would be a good idea to get an interpretation from RSPA (172.502(a)(2)). a. International Placarding Exception- The prohibited placarding provisions of 172.502(a) do not apply to motor vehicles, rail cars, unit load devices, freight containers, or other bulk packagings placarded in accordance with the: 1. IMDG Code 2. UN Recommendations 3. Canadian TDG Regulations 58 (0691) O 1991 GSI Consider Services Inc., Branson, MO 6S616 Repented with permmioo. All rigtas reserved. ABDOO130737 This PERMISSIVE provision is to facilitate the international transportation of Dangerous Goods (Hazardous Materials) by permitting Placarding which would otherwise be prohibited because the materials did not meet the definition of a Hazardous Material under 49 CFR or the International Placards were similar to but different from the 49 CFR Placards (172.502(b)). G. Placard Specifications- There are very specific Placarding Specifications relating to the 414 kPa (60 p.s.i.) Mullen Test requirements; the 30 day exposure test; minimum size requirements of 273 mm (10.8 inch) per side with a solid line border approximately 12.7 mm (.5 inches) from each edge; and other design requirements in 172.519. 1. Display of Class or Division Numbers- TheClassorDivisionNumberasshownin172.522-172.560 is required for Placards corresponding to the Primary Hazard Class or Division. The Class or Division Number may not be displayed on a Placard corresponding to a Subsidiary Risk (172.519(b)(4)). GSI CR: Subsidiary Risk Definition, 6; B. Classification, 7; B. Labeling, 40 2. Text on Placards- Except for the RADIOACTIVE (Class 7) Placard text on placards is optional (172.519(b)(3)). 3. Color- The colors on placards must meet the requirements of 172.519(d). Note: The illustrations of Placards in this Section are in "black and white''. Full color illustrations of the DOT Placards are contained in the "Official DOT Hazardous Material Warning Placard Chart'' in Appendix 3. 59 (0691) O 1991 GSI CoojMter Service Inc., Bnnson, MO 65616 Reprinted with pcrmmwa Ail rights reserved. ABDOO130738 RESERVED- Intentionally left Blank, 60 (0691) O 1991 GSi CoafWtcr Servicci lac., Branson, MO 63416 Rcprisud with pcnmssioo. All rights moved. ABDOO130739 HCBLA.B.CS OF THE CLASS 3 TO COMBUSTIBLE EXCEPTION A. What is it? This Exception permits Class 3 liquids (Flammable liquids) having a Flashpoint at or above 38C (100F) and not more than 60.5C (141F) which are not being transported bv air or vessel to be reclassified as Combustible Liquids (173.150(f)(1)). Illustration: A Class 3 Paint having a Flashpoint of50C (122F) may be reclassified to a Combustible liquid for domestic transportation by highway and rail but not air or vessel. B. Advantages- When used in conjunction with the Combustible Liquid Non Bulk Packaging Exception contained in 173.150(f)(2) it permits a material that would normally be required to meet Class 3 requirements to be Offered, Accepted, and Transported within the transportation system under the less stringent requirements that apply to Combustible Liquids. As illustrated below, these less stringent requirements can range from complete deregulation for most non bulk packagings to the use of non specification packaging in the case of bulk packagings. 1. Illustrations Non-Bulk Packagings- For all practical purposes a 220 L (55 Gallon) drum of a Class 3 Paint having a Flashpoint of50C (122) reclassified to a Combustible liquid under the "Class 3 To Combustible Exception" contained in 173.150(f)( 1) is NO LONGER regulated asa Hazardous Material under the provisions of49 CFR. The Combustible Liquid Non Bulk Packaging Exception states that the Hazardous Material regulations "do not apply to a material classed as a combustible liquid in a non bulk packaging unless the combustible liquid is a hazardous substance is a hazardous waste " (173.150(f)(2)). Bulk Packagings- A 12,000 L (3000 Gallons) Cargo Tank a Class 3 Paint having a Flashpoint of50C (122) reclassified to a Combustible liquid underthis Exception will not be required to be packaged in either UN Standard or DOT specification packagings (173.150(f)(3)). C. Caution- The Class 3 to Combustible liquid exception contained in 173.150(f)(1) does not apply to transportation by air or water and has absolutely no applicability to the Offering and Accepting of Dangerous Goods for transportation by air or water under the Dangerous Goods Regulations contained in ICAO, IATA, or IMDG Code. The Non Bulk Packaging Exception contained in 173.150(f)(2) does not apply to Combustible liquids that are also Hazardous Wastes or Hazardous Substances. 61 (0691) O 1991 GSI Computer Services toe.. Brawn, M06HI6 Reprinted with permission. All rights reserved. ABDOO130740 THE A.B.CS of the CONSUMER COMMODITY (ORM-D) EXCEPTION A. What is a "Consumer commodity1*? In general terms a "Consumer Commodity" is a Hazardous Material AND its packaging that is distributed in a form intended or suitable for sale at the retail level for consumption by individuals for the purposes of personal care or household use including drugs and medicines (171.8). In addition the Hazardous Material must be Offered for transportation under the terms ofan appropriate Consumer Commodities (ORM-D) Reclassification Exception. Nothing is bom a Consumer Commodity. ALL Consumer Commodities are Hazardous materials that are eligible for and Offered in accordance with an appropriate Consumer Commodities (ORM-D) Exception. For all practical purposes it is a domestic reclassification exception that permits those Harardous Materials meeting the requirements of the exception to be reclassified from whatever Hazard Class or Division they are currently in tfi the ORM-D Hazard Class and to be Offered for transportation using the Proper Shipping Name Consumer commodity. Every material shipped as a Consumer commodity can be traced back to another Hazard Class or Division and Proper Shipping Name. Illustration: A four (4) ounce package of"Va Va Boom" perfume containing flammable solvents and having a Flashpoint of 36C (97F) would normally be classed as a 3, Packing Group III and Offered for transportation using the Proper Shipping Name Perfumery products. This product is packaged and intended for sale at the retail level for personal care use. IE it also meets the other requirements for the Consumer Commodity (ORM-D) Reclassification Exception its Hazard Class changes to ORM-D and its Proper Shipping Name becomes Consumer commodity. B. The Four Step Consumer Commodity ORM Reclassification Exception- The Consumer Commodities, ORM-D Exception reclassification process is a four (4) step procedure. The Hazardous Material and its packaging must pass ALL FOUR (4) STEPS or its not eligible to be reclassified and shipped under this exception. 1. DETERMINE WHETHER OR NOT THE MATERIAL AND ITS PACKAGING MEET THE DEFINITION OF A "CONSUMER COMMODITY" AS CONTAINED WITHIN 171.8. The material AND its packaging must be suitable OR intended for sale at the retail level for consumption by individuals for personal care or household use. Application: A four (4) ounce package of"Va Va Boom" perfume meeting the definition ofa Class 3, aone(l) liter package of Aldrin Insecticide meeting the definition ofa Division 6.1, and a 16 ounce cylinder of Propane Fuel meeting the definition of Division 2.1 being shipped to Walmart for sale all meet this definition. They are packaged and suitable for sale at the retail level for consumption by individuals for personaLcare_oiihousehold use. On the other hand a 55 gallon drum of "Va Va Boom" being shipped to a plant for bottling would not meet this definition because the size ofthe packaging is NOT SUITABLE for sale at the retail level for use by individuals for personal care or household use. The retail personal use criteria is pertains to suitability or intent, not actual use or intent. 2. DETERMINE WHETHER OR NOT THERE IS AN EXCEPTION AUTHORIZATION FOR THE MATERIAL IN Column (8A) OF THE 172.101 TABLE (HMT). It can generally be said that if there is no Exception Authorization permitted in Column (8A) of the HMT for the entry covering the Hazardous Material it is NOT ELIGIBLE to be reclassified and shipped as a Consumer commodity, ORM-D. Application: Reference to Column (8A) in either the 172.101 Table (HMT) or Figure 63A indicates that there is an Exception authorized in Column (8A) for both Perfumery products and Propane but not for Aldrin. Aldrin would not be eligible for the exception because there is no Exception Authorized in Column (8A). Perfumery products and Propane might be eligible for reclassification, because there is an Exception Authorization Section listed in Column (8A) of the 172.101 Table for these materials, IF they can also meet the requirements of Steps 3 and 4, forthe Exception. 62 (0691) O 1991 GS1 Computer Services Inc., Branson, MO 65416 Reprinted widi permasioo. All rights reserved. ABDOO130741 3. DETERMINE IF AN ORM-D EXCEPTION IS AUTHORIZED IN THE SPECIFIC SECTIONS APPLICABLE TO THE MATERIAL. Generally the "Consumer Commodity Authorization", ifany, will be found in the Exception Authorization Section referred to Column (8A) the 172.101 Table in a paragraph entitled "Consumer Commodities". In addition to meeting Steps #1 & #2 above a specific Consumer Commodities Exception must be authorized for the material in the Section(s) in Part 173 referred to by the 172.101 Table. Application; Reference to the Exceptions Authorization Sections for the Perfumery products and Propane, 173.150 and 173.306 respectively indicates that there is a Consumer Commodities exception contained in paragraph 173.150(c) for Perfumery products and in paragraph 172.306 (h) forPropane. Ifthe Hazardous Materials, as packaged, meet Step #4 they are eligible to be reclassified and Offered for transportation as a Consumer commodity, ORM-D. If not they are not. 4. DOES THE PARTICULAR HAZARDOUS MATERIAL AND ITS PACKAGING MEET THE CONDITIONS CONTAINED WITHIN THE SPECIFIC CONSUMER COMMODITY EXCEP TION PARAGRAPH? In addition to meeting the requirements of Steps 1-3 above the Hazardous Material and its packaging must meet all the conditions contained within the Consumer Commoditties Exception paragraph applicable to the material. At a minimum these conditions will include those necessary to ship the material under the "Limited Quantity Exception". In some cases, as illustrated by paragraph 173.306(h) forthe Propane, there will be additional conditions that must be met. If either the Hazardous Material or its packaging does not meet the conditions of the applicable Consumer Commodities Exception paragraph the Hazardous Material may not be reclassified as an ORM-D and Offered for transportation as a Consumer Commodity. Application: Reference to paragraph 173.150(c) would permit a 4 ounce package of "Va Va Boom", a Class 3, Perfumery product, packaged in one (1)4 ounce glass bottle inside a "non specification" fiberboard box and otherwise meeting the conditions of 173.150 to be reclassified as an ORM-D and Offered for transportation as a Consumer Commodity. On the other hand reference to 173.306(h) indicates that a 16 ounce cylinder of Propane does not meet the requirements of this Consumer Commodity Exception paragraph. Even though it meets the first three (3) steps of the process the 16 ounce cylinder of Propane MAY NOT be reclassified as an ORM-D and Offered for transpor tation as a Consumer Commodity. Hazardous Material Table - 172.101 Table Hazardous Non materials Pack- Bulk Proper Shipping ing Special Excep- Pack- Names group Provis. tions agings (2) (5) (7) (8A) (8B) Aldrin, liquid II None 202 Perfumery products II T7,T30 150 III B1,T7, 150 T30 202 203 Propane 306 304 FIGURE 63A 63 (0691) 01991 GSI Compute* Services Inc., Bnnsoo, MO 63616 Reprinted wiili penxosion. All right* reserved. ABDOO130742 C. General Effect Of Reclassification- Ifa Hazardous Material is eligible for and reclassified as an ORM-D its Proper Shipping name becomes Consumer commodity and that is the entry in the 172.101 Table that becomes applicable to the Hazardous Material. A comparison between the Consumer commodity and Perfumery products entries in the 172.101 Table or Figure 64A below shows that once reclassified as an ORMD there is nothing in the system that alerts Emergency Responders, transportation workers and others to the previous Hazard Class or Proper Shipping Name. It is this author's opinion that Hazardous Materials that are properly reclassified, packaged, and otherwise shipped in accordance with the Consumer Commodities Exceptions pose minimal risk while being transported in the transportation system. The words properly reclassified, packaged, and otherwise shipped in accordance withthe regulations must be stressed. It is his further opinion that Hazardous Materials Offered fortransportation under this exception that are not properly reclassified, packaged, and otherwise shipped in accordance with the regulations can, because of the broad scope of this exception, significantly increase the risks associated with the transportation of such materials. Symbol (1) Hazardous Material Table-172.101 Table Hazardous materials descriptions and proper shipping names (2) Hazard Identificlass or cation Division Numbers (3) (4) Pack ing group (5) Label(s) Required (If not excepted) (6) D Aldrin, liquid D Consumer commodity Perfumery products 6.1 NA2762 II ORM-D None 3 UN1266 II Propane see also Petroleum gases, liquefied 2.1 UN1978 POISON None FLAMMABLE LIQUID FLAMMABLE GAS FIGURE 64A D. Specific Effects ofthe Consumer Commodities ORM-D Exception- The following changes in the normal regulatory compliance procedures result when a particular Hazardous Material is shipped as a Consumer commodity, ORM-D: 1. IDENTIFICATION a. Proper Shipping Name: Consumer commodity b. Hazard Class: ORM-D c. ID Number There is no UN or NA Number. In effect, for the purposes of transportation, the Hazardous Material LOSES ITS PREVIOUS IDENTITY and becomes a Consumer commodity. As discussed in C. above and illustrated in Figure 64A if a Perfumery products is shipped as a Consumer commodity the Proper Shipping Name changes from Perfumery products to Consumer commodity; the Hazard Class changes from Class 3 to ORM-D; and the ID Number of UN 1266 that applies to the Perfumery products entry no longer applies. The effects ofthis Exception on Marking and Labeling is illustrated in Figure 65A. 2. PACKAGING- One of the main advantages of the Consumer Commodities ORM-D Exception is that the packaging does not have to meet the UN Standard or U.S. DOT Specification packaging requirements. This does not mean that there are no packaging standards that apply however because, in general, the 64 (0691) 01991 GSI ComputerSavkes Inc., Bnnson,M06$616 Repratud widi pemistioa. All rights racmd. ABDOO130743 combination packagings requirements ofthe appropriate Limited Quantity Exception will require the use of strong outerpackagings and compliance with the General Packaging Requirements ofSubpart B ofPart 173. (173.156(b)). 3. MARKING AND LABELING- With the exception ofthe ID Number marking packages containing Consumer Commodities must be marked with all other applicable information required to be marked on non bulk packages ofHazardous Materials (172.300(a)). The Labeling required by Subpart E ofPart 172 does not apply to Consumer commodities (172.400a((b)). Perfumery products UN1266 From: Smell Sweet Inc. 10 Scent Blvd., Mecca,. CA 92254 Braschler Music Show Gretna Road Branson, MO 65616 GSI bOT-12B65l 4G/X30/S/91 USA/+GS0001 (al. ORM-D Designation- In addition to all other required Markings each package containing Consumer commodities must be marked on at least one end or side immediately following or below the Proper Shipping Consumer commodity with the designation ORM-D or ORM-D-AIR, as appropriate. The appropriate ORM-D Designation must be in a rectangle that is approximately 6.3 mm (0.25 inches) larger on each side than the designation itself. The ORM-D designation for a shipment ofa Consumer commodity, ORM-D other than by air is illustrated in Figure 65A. 65 (0691) O 1991 GSI Computer Services Inc., Brensoa, MO 65616 Reprinted with pennjssion. All rights reserved. ABDOO130744 4. SHIPPING PAPERS- Shipping Papers are not required for "Consumer commodity" shipments unless: 1. Being shipped by Air ((172.200(b)(3)) OR 2. The Consumer commodity is regulated as either a Hazardous Substance or Hazardous Waste. The Shipping Paper exception contained in the appropriate Consumer Exception paragraph used for the reclassification does not apply to Hazardous Substances or Hazardous Wastes. GSI CR: Hazardous Substances, 17; Hazardous Wastes, 21; Shipping Papers, 43 5. PLACARDING- There are no ORM-D placards and Placarding is not required for ORM-D materials (172.500(b)(2)). E. Consumer Commodity. ORM-D "Retail Outlet" Exception- Paragraph 173.156(b) permits an additional limited exception to the strong outside packaging requirements of Sections 173.150-173.155 and 173.306 and the ORM-D Designation marking required by 172.316 for ORM-D materials unitized in carts, cages, or similar overpacks when beingtransported by Private or Contract Motor Carrierfrom a distribution center to a retail outlet. F. Domestic Exception Only- The Consumer Commodities ORM-D Exception is a U.S. (Domestic Exception) and has no general applicability when shipping Internationally underthe provisions ofIATA, ICAO, orthe IMDG Code. 66 (0691) 01991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130745 Appendices ABDOO130746 UN PERFORMANCE ORIENTED PACKAGING br. Gary J. Groman^BSBA. JD Detailed Design and Construction Standards The "detailed design and construction standards" used for packagings by the United States under 49 CFR and similar, but different standards used by other countries throughout the world, has provided an excellent level of safety for the safe transportation ofDangerous Goods throughout the world for many years. Such standards are however, complex, numerous, and differ in specifics from country to country. In some cases, they differ for transportationby different modes within the same country. In the United States alone, the 1990 Edition of49 CFR contains over 10 different "detailed design and construction standards" for closed head steel drums, some of which may be used for transportation by air and some of which may not (Subpart D of Part 178). The problems associated with the different but similar "detailed design and construction standards" of various countries throughout the world and with the transportation ofthe different packagings authorized by one country into another and their impact on free trade between countries were obvious. Also ofprimary concern was the fact that the "detailed design and construction standards" ofone country were very seldom, if ever, understood or enforced by those outside of the country that used the specific standard. There was no one packaging safety standard that could be used by those having a safety responsibility within the international transportation system whether carrier, shipper, or enforcement personnel, to determine whether or not a particular packaging was authorized in any given situation. The "UN Performance Oriented Packaging (POP) standard" was developed by the UN Committee of Experts on the Transport of Dangerous Goods to address these problems and provide for packaging safety while facilitating the free flow of these packagings within international commerce. Source of UN Performance Oriented Packaging fPOP) Standards Generally, it can be said that "UN Performance Oriented Packaging (POP) standards" are developed by the UN Committee of Experts on the Transport of Dangerous Goods and published in Chapter 9 of the "UN Recommendations for the Transport of Dangerous Goods" commonly called the "Orange Book". This serves as the basis and authority for the Performance Oriented Packaging requirements published in the ICAO Technical Instructions For The Safe Transport of Dangerous Goods By Air (ICAO) and the International Maritime Dangerous Goods Code (IMDG). In addition, it serves as the basis for the Performance Oriented Packaging standards adopted by individual countries. In the United States the Performance Oriented Packaging standards for non bulk packagings in ICAO have been authorized forallairtransportation since January 1,1983. In addition, although not mandatory until at least October 1, 1996 for domestic transportation, 49 CFR, as of January 1,1991, permits the use ofthe UN Performance Oriented Packaging standards for non bulk packagings for all domestic transportation of Hazardous Materials (171.14(b)). One source of obtaining the publications shown in bold type is (American Labelmark (Label Master) 1-800-621-5808?) UN Performance Oriented Packaging (POP) Standards The UN Performance Oriented Packaging (POP) standard is based on the anticipated performance of the packaging within the transportation system rather than the detailed design and construction ofthe packaging. Although there are minimal construction standards for Performance Oriented Packaging (POP) contained in the UN Publications mentioned above they are expressed in general terms rather than the detailed terms used for "design and construction" based packaging standards. As an example, the construction standards for the one closed head_steel drum authorized under the UN Performance Oriented Packaging standard, the UN1A1 steel drum, take up about 25% ofone (11 page. The detailed construction standards forjust 3oftheoverl0 authorized closed head steel drums contained within Sub Part B, Part 178 ofthe 1990 Edition of49 CFR, those in the DOT17 series, take up over 7 full pages (178.115-178.117). The primary emphasis of Performance Oriented Packaging standards is to secure the level ofsafety desired by ensuring the ability ofa given package type to successfully pass a series ofperformance tests designed to test Appendix 1-1 (0691) 01991 GS1 Con^uter Services lac., Branson, MO. All rights reserved. ABDOO130747 its ability to withstand the normal conditions incident to transportation rather than its design or construction. UN Performance Oriented Packaging Standards Apply to Non Bulk Packaging AsofJanuary 1,1991 the UN Performance Oriented Packaging standards that have been developed apply to non bulk packagings, those having a rated capacity ofno more than 400 kg (880 lbs) for solids or an internal volume ofno more than450 L (118.9 Gallons) for liquids. They do not apply to cylinders. Radioactive Materials and bulk packagings (49 CFR - Page 52403 ofthe Federal Register dated 12/21/90 and 9.1.2 ofthe "UN Recommendations for the Transport of Dangerous Goods"). UN Packing Groups Most ofthe Performance Oriented Packaging tests are based on the Packing Group for which the packaging is being tested (qualified). Most Dangerous Goods are assigned to a Packing Group which indicates their relative degree ofdangerwhile in the transportation system (49 CFR 171.8; IntroductoryNote2to Part 3 in ICAO; 3.0.6 inIATA;and 1.2ofAnnexItotheIMDGCode). The Hazard Class gives the type ofHazard. The Packing Group gives the degree ofthat hazard. This authorprefers to look at it this way, the Hazard Class tells us that a material is regulated as a Hazardous Material or Dangerous Goods and the Packing Group tells us just how regulated it is: Packing Group I Packing Group II Packing Group III Greatest Danger (Most Regulated) Moderate Danger (Moderately Regulated) Least Danger (Least Regulated) Performance Oriented Packaging Tests - Overview The standard UN Performance Oriented Packaging tests and the general purpose of each is as follows: Test Type Ability of Package/PackaginfrTo Drop Leak proofness Hydrostatic Pressure Stacking Contain and protect the Dangerous Goods if the package is dropped. Prevent leakage of liquids under conditions of normal transport. Prevent leakage of liquids under pressure. Maintain stability w/in a stack while stacked with similar type packages. UN Performance Testing General Pre Testing Requirements In most cases the packagings to be used in testing will require some special preparation prior to the conduct of the actual tests (49 CFR 178.602; 7;4.2 in ICAO; 6.2.11 -6.2.15 in IATA; and 8.3 ofAnnex I to the IMDG Code). At a minimum this will include: 1. All Tests - Paper or Fiberboard: Paper or Fiberboard packagings must be preconditioned for 24 hours in an atmosphere maintained within certain temperature and relative humidity. Although there are choices the preferred is a relative humidity of 50% plus or minus 2% at a temperature of23C (73F) plus or minus 2C (4F) (49 CFR 178.602(d); 7;4.2.3; 6.2.13 in IATA; and 8.3.3 of Annex I to the IMDG Code). 2. All Tests - UN4G Fiberboard Box: The water resistance ofthe outer layer ofthe Fiberboard used in the UN4G Fiberboard box has to be such that the increase in weight, as determined by a test carried out over a 30 minute period using the Cobb method ofdetermining water absorption, does not exceed more than 155 grams per square meter (0.0316 lbs per square foot) (49 CFR 178.516(b)(1); 7;3.1.10.1 in ICAO; 6.1.21 in IATA; and 7.11.1 of Annex I to the IMDG Code). Appendix 1-2 (0691) 01991 GSI Computer Services Inc., Bnnson,MO. All rijha reserved. ABDOO130748 3. All Tests - Plastic Drums, Jerri Cans* and Composite Packagings: Underthe UN Packaging Standard a chemical compatibility/permeability test must be performed on the actual samples ofplastic packagings used for all tests where the plastic of the packaging will come in contact with the material being transported (7;4.2.4 of ICAO; 6.2.14 of IATA; and 8.3.5 of Annex lofthe IMDG Code). The U.S. standard is different. See 173.24re1 and page 6 of this Appendix. DROP TEST 1. Number of Samples and Type of Drop: The number of packages to be dropped and the drop orientation depends on the type ofpackaging being tested. A UN4G combination packaging would require five (5) packages, one for each drop, prepared as for transportation and conditioned as required. Individual packagings would be dropped flat on the bottom, top, one(l)long, one (1) short side and on a comer. The number and type of drops for other packaging types can be found in 49 CFR 178.603; 7;4.3 of ICAO; 6.2.15 of IATA; and 8.4 of Annex lto the IMDG Code. 2. Required For: All packages prepared and filled as for transportation. 3. Special Preparation of Samples Unique to Test: a. All Packagings - Must be filled to not less than 95% of their capacity for solids and to not less than 98% for liquids (49 CFR 178.602(b); 7;4.3.2 of ICAO; 6.2.11 of IATA; and 8.4.2 of Annex lto the IMDG Code). b. Plastic "Packagings: Tests for plastic drums, jerricans, boxes, composite packagings, and combination packages with inner plastic packagings, other than bags or expanded polystyrene boxes, must be performed when the temperature of the samples and their contents has been reduced to -18C (0F) or lower (49 CFR 178.603(c); 7;4.2.1 of ICAO; 6.2.16of IATA; and 8.3.1 of Annex lto the IMDG Code). 4. Description ofTest & Drop Height- Packages prepared as fortransportation are dropped from the appropriate height onto a non resilient, rigid, horizontal and flat surface. The number and type ofdrops depend on the specific packaging being tested. The drop heights will depend on the Packing Group of the material for which the packaging will be used as follows: UN Packing Group Drop Height I 1.8 m (70.8") II 1.2 m (46.8") III .8 m (30")' a. If the Relative Density exceeds 1.2 and the test is performed with water, the drop heights should be computed by multiplying the Relative Density by the factor indicated below as appropriate for the UN Packing Group for which it is being tested: UNJPacking Group Drop Height I Relative Density x 1.5 m II Relative Density x 1.0 m III Relative Density x .67 m Illustration: The drop height for a packaging being tested using water for a material with a Relative Density of 1.6 and Packing Group II would be 1.6 m (63"). 5. Criteria for Passing Test: There is no leakage ofmaterial in the package, no release ofthe inner packagings from the outer packaging, and no other indication of any damage likely to affect safety during transportation. Except for combination packagings, each packaging containing liquids must be leakproofwhen equilibrium has been reached between the internal and external pressures. It should be noted a slight discharge from a drum, jerrican, box, or bag immediately after impact need not be considered a failure provided no further leakage occurs (49 CFR 178.603(f)(5); 7;4.3.5 of ICAO; 6.2.19 of IATA; and 8.4.5 of Annex lto the IMDG Code)). Appendix 1-3 (0691) O 1991 GS1 Conjurer Services lac., Branson, MO. All rights reserved. ABDOO130749 1. Number of Samples; LEAKPROOFNESS TEST a. Design Qualification Testing - Three (3) of each different packaging. ach must pass. b. Production/Reconditioning Testing: All packagings (49 CFR 178.604(b); 7;4.1.9 of ICAO; 6.2.9 of IATA; and 3.12 of Annex 1 to the IMDG Code). 2. Required For. All packagings designed to contain liquids except inner packagings of combination packagings. 3. Special Preparation of Samples Unique to Test: See Special Note: 6 below. 4. Description of Test: Generally the packaging to be tested will be placed under water and restrained. Compressed gas will be applied to the packaging at a pressure not less than that shown below as appropriate for the Packing Group for which it is being tested (49 CFR 178.604(e); 7;4.3.2 of ICAO; 6.2.22 of IATA; and 8.5.4 of Annex 1 to the IMDG Code): UN Packing Group Test Pressure (Gauge! I Not less than 30kPa (4 psi) II Not less than 20kPa (3 psi) III Not less than 20kPa (3 psi) 5. Criteria for Passing Test: No leakage of air from the packaging. Generally this will be indicated by the formation ofair bubbles. 6. Special Note: This test, when required, must be performed on all Production Packagings as well as Pre Production (Design Qualification) packagings. Basically this means that this test must be conducted on the packaging prior to production to qualify it and on each produced packaging before its initial use. It must also be performed aftereach reconditioning priorto reuse. The Design Qualificationtestsmusthavetheirown closures properly fittedto the packaging. The Productionand Reconditioning tests do not requirethat thepackages be fitted with theirown closures (49 CFR 178.604(c); 7;4.4.3 ofICAO; 6.2.25 oflATA; and 8.6.1 ofAnnex 1 to the IMDG Code). INTERNAL (HYDROSTATIC) PRESSURE TEST 1. Number and Type: Three (3) samples per design type and manufacturer must be tested. 2. Required For: All plastic, metal, and composite packagings intended to contain liquids. This test is not required on inner packagings ofcombination packagings unless they are intended for transportation bv air (49 CFR 178.605(a); 7;4.5.1 ofICAO; 6.2.23 of IATA; and 8.5.5 of Annex 1 to the IMDG Code). 3. Special Preparation of Samples Unique to Test: - None 4. Description of Test: Packagings to be tested are filled with water or other suitable liquids completely so as to eliminate all air pockets. Using a hydrostatic pressure supply the appropriate amount of pressure is applied internally, through a fitting that has been installed on the packaging for this puipose. The appropriate test pressure must be maintained for five (5) minutes for metal and composite packagings ofglass, porcelain, or stoneware and 30 minutes for plastic and composite packagings ofplastic material. Test Pressures: Except for packagings designed and being tested for Packing Group I, the Test Pressure will vary depending on the Vapor Pressure ofthe material and on which of the three (3) authorized testing methods used. Packagings being tested for Packing Group I must be tested at a minimum test pressure of250kPa (36 psi) (49 CFR 178.605(d); 7;4.5.3 ofICAO; 6.2.27 of IATA; and 8.6.4 of Annex I to the IMDG Code). Appendix 1-4 (0691) O 1991 GSI Computer Services Inc., Brbsoq,MO. AU rights reserved. ABDOO130750 5. Criteria for Passing Test: Each packaging tested must not leak. 6. Pressure Requirements for Air Transportation: For all practical purposes the inner packaging exception DOES NOT apply to airshipments because ofGeneral Packaging Requirements which create minimum pressure requirements (49 CFR 173.27(c); 3; 1.1.6.1 ofICAO; and 5.0.13 ofIATA). All packagings transported by air for which the retention of liquids is their primary function must be capable of withstanding, without leakage, the following pressures as applicable to the Packing Group: (1.) All packagings other than inner packagings ofcombination packagings: A Minimum pressure of 250kPa (36.3 psi) (49 CFR 178.605(d); 7;4.5.4 of ICAO; and 6.2.28 of IATA). (2.) Inner Packagings ofCombination packagings: All packagings must be capable ofwithstanding an internal pressure which produces a pressure differential of not less than 95kPa (13.8 psi) OR a pressure related to the vapor pressure of the liquid to be transported determined in accordance with one (1) of the two(2) methods permitted WHICHEVER IS GREATER (49 CFR 173.27(c); 3;1.1.6.1 of ICAO; and 5.0.13 of IATA). b.. Packing Groups II: All packagings must be capable ofwithstanding an internal pressure which produces a pressure differential ofnot less than 95kPa (13.8 psi) OR a pressure related to the vaporpressure ofthe liquid to be transported determined in accordance with one (1) ofthe two(2) methods permitted WHICHEVER IS GREATER (49 CFR 173.27(c); 3;1.1.6.1 of ICAO; and 5.0.13 of IATA). c. Packing Group III: (1). Class 3 or Division 6.1 Qnlv: All packagings must be capable ofwithstanding an internal pressure which produces a pressure differential of not less than 75 kPa (10.88 psi) OR a pressure related to the vapor pressure of the liquid to be transported determined in accordance with one (1) of the two (2) methods permitted WHICHEVER IS GREATERf49 CFR 173.27(c); 3;1.1.6.1 of ICAO; and 5.0.13 of IATA). (2). All Other Classes and Divisions: All packagings must be capable of withstanding an internal pressure which produces apressure differential ofnot less than95 kPa(13.8 psi) ORapressure related to the vapor pressure ofthe liquid to be transported determined in accordance with one (1) ofthe two (2) methods permitted WHICHEVER IS GREATER (49 CFR 173.27(c); 3; 1.1.6.1 of ICAO; and 5.0.13 of IATA). STACKING TEST 1. Number of Samples: Three (3) test samples for each packaging to be tested. 2. Required For: All packagings except bags (49 CFR 178.606(a); 7;4.6.1 of ICAO; 6.2.30 of IATA; and 8.7 of Annex 1 to the IMDG Code). 3. Special Preparation of Samples Unique to Test: a. AH Packagings - Must be filled to not less than 95% oftheir capacity for solids and to not less than 98% for liquids (178.602(b)). 4. Description of Test: Each test sample shall be subject to a force applied to the top surface ofthe sample that is equivalent to the total weight of identical packages which might be stacked on top of it during transportation. In determining the amount of force to be applied the minimum height ofthe stack including the sample must be no less than 3 m (10 ft). The force must be applied to the top ofthe sample in the same manneras applied by actual packages stacked on top of it; evenly dispersed etc. APPLICATION: A sample having a height of304.8 mm (12 in) weighing a Gross Weight (Mass) of6 kg. (13.2 lbs.) would be subjected to a force ofat least 54 kg (1191bs) because, including the sample, nine (9) more identical packages would be required to reach the minimum stacking height of 3 m (10 ft). The force must be applied for Appendix 1-5 (0691) 01991 GS1 Confute? Soviets toe., Branson, MO. All rights reserve! ABDOO130751 a period of 24 hours except in the case ofplastic 6HH composite packaging, drums, and jerricans, intended for liquids, in which case, it must be applied for a period of 28 days at a temperature of not less than 40C (104F) (49 CFR 178.606(d); 7;4.6.4 of ICAO; 6.2.33 of IATA; and 8.7.3of Annex 1 to the IMDG Code). 5. Criteria for Passing Test: a. Evaluation - No test sample may leak, show any deformation or distortion likely to cause instability in stacks of packagings or reduce its strength, or any deterioration which could adversely affect transpor tation safety. b. Stability Determination - Stacking stability is considered adequate when after the Stacking Test and evaluation described in 4. and 5.a. above have been completed, and, in the case ofplastic receptacles after cooling to ambient temperature, two (2) filled packages of the same type are placed on each filled test sample and maintain their position for a minimum of one (1) hour. VIBRATION STANDARD (HM-181 Onlvl Packagings being tested under Subpart L ofPart 178 of49 CFR must also meet the vibration standard requirements ofSection 178.608 (173.24a(a)(5)). There is no similar test required under the UN Testing scheme as ofJanuary 1,1991 however, we at GSI recommend that the Vibration Standard be met for all non bulk packaging marked as complying with UN Performance Oriented Packaging standards. Although an argument can be made that the authority in 171.11 and 172.12 permits the certification and use ofUN packaging tested under ICAO orthe IMDG Code, which does not require the vibration test, it is a basically useless argument in terms ofpotential civil liability and standardization of packaging for both domestic and international transportation. 1. Number of Samples: Three (3). 2. Required For: All packagings. 3. Special Preparation: Selected at random and filled and closed as for shipment. 4. Description ofthe Test: Placed on a vibrating platform and restrained from horizontal movement but left free to bounce, rotate, and move vertically. The test must be performed for one (1) hour at a frequency that causes the package to be raised from the platform in such a manner that a piece of material such as steel strapping or paperboardcanbepassedbetweenthebottomofanypackageandtheplatform.adistanceofapproximately 1.6mm (.063"). Immediately following the period ofvibration each package must be removed from the platform, turned on its side and checked for any indication of leakage. 5. Criteria For Passing Test: No rupture or leakage from any package. Compatibilitv/Permeabilitv Testing For Plastic Packagings Although there is no specific UN Compatibility/Permeability Test specified as part of the UN Performance Oriented Packaging Tests, there are general requirements that require the consideration of these factors for all plastic packagings to be used in the actual UN Performance Tests ( Part 7:4.2.4 of ICAO. 6.2.14 oflATA, and 8.3.5 of Annex I to the IMDG Code). The bottom line is that, under the UN standards, some sort oftest to determine the permeability and compatibility ofa plastic packagings or receptacles for their intended contents or, an authorized equivalent, must be performed on all the actual plastic packagings to be used in the Drop, Leakproofness, Hydrostatic, or Stacking tests involving the use ofthose packagings. In general terms, ` `Permeability** is a measure ofthe amount ofmaterial that passes through the packaging during the test period. It is calculated as the difference in the gross weight (gross mass) ofthe package at the end ofthe test period from the original gross weight at the beginning ofthe test period and will generally be expressed in terms ofpercentage ofthe original gross weight ofthe package. Compatibility has to do with whether or not the intended contents of the package cause permanent deformation, deterioration, cracking, excessive corrosion, Appendix 1-6 (0691) O 1991 GSlCocqpuaScrvket Inc., BciBsoa,MO. Ml rights reserved. ABDOO130752 embrittlement, leakage, rupture or other defects likely to cause leakage or a packaging failure. Basically the test involves packaging the material as it will be offered for shipment and storing it for a prescribed period oftime at a prescribed temperature. After the prescribed period, the permeability measurements are taken and a visual inspection is conducted to see ifthe packaging integrity has been effected. Some ofthe acceptable test methods are described in Part 7;4.2.4 ofICAO; 6.2.14 ofIATA, 8.3.5 ofAnnex lofthe IMDG Code, Appendix B to Part 173 of49 CFR, and in Annex A1 of ASTM D4919-89. It is again stressed that the compatibility ofplastic packagings for the material they are going to contain must be established PRIOR to conducting the UN Performance tests using an acceptable test method. The actual packages used to perform the UN Performance tests must be the packages used in the Compatibility Test. This helps insure that any potential compatibility problems will not impact in an unfavorable manner on the ability of the packagings to pass the required performance tests. MANUFACTURER The "manufacturer" is defined by 49 CFR 171.8 as "any person who certifies that a packaging complies with a UN or DOT standard, including a person who applies or directs another to apply a DOT specification marking or a UN mark to a packaging." DESIGN QUALIFICATION TESTING The entire UN performance oriented packaging system is designed to insure that the design, construction, and assembly ofall packages meet the Performance Oriented Qualification tests at the start ofproduction initially for the package design and for each new or different packaging (178.601(d)). Testing Documentation and Retention: In addition to conducting the tests the manufacturer must keep records documenting the tests at each location where that packaging is manufactured and at each location where the design qualification tested are conducted. These records must be kept for as long as the packaging is produced and for at lest two (21 years thereafter. At a minimum the records should include "specific types, dates, locations, packaging specifications, test specifics (drop heights, hydrostatic pressure, etc.), results, and test operators' names or name of person responsible for the testing" (178.601(k)( 1 ))- PERIODIC RETESTING Periodic Retesting must be done by the manufacturer to insure that the packaging produced and used is capable ofpassing the design qualification tests. For single or composite packagings this retesting must be no less than once each 12 months. For combination packagings this retesting must be done no less than once each 24 months (178.601(e)). The times given are the maximum times between tests. It should be stressed that it is the manufacturer's responsibility to insure that the packaging as used is at all times and in all respects capable of passing the design qualification tests and other wise is in compliance with all applicable regulations. This may require more frequent testing. Note too that time period is based on the passage of months not years. A single packaging tested on July 1,1990 would have to be retested within 12 months ofthat date or no later than June 30, 1991. Testing Documentation and Retention: In addition to conducting the periodic retests the manufacturer must keep records documenting the tests at each location where that packaging is manufactured and at each location where the period retests are conducted. These records must be kept until the tests are successfully performed again and for at least two (2) years from the date of each test. At a minimum the records should include "specific types, dates, locations, packaging specifications, test specifics (drop heights, hydrostatic pressure, etc.), results, and test opeators' names or name ofperson responsible for the testing" (178.601(k)(2)). Appendix 1-7 (0691) O 1991 GSI Computer Services lac., Bnnson,MO. All rights reserved. ABD00130753 UN SPECIFICATION PACKAGE MARKING General Requirements- The manufacturer must mark every package that is required to conform to the UN Standard with the appropriate information indicated below in the sequence indicated. The markings must be stamped, embossed, printed, burned; or otherwise marked on the packaging so as to provide adequate accessibility, permanency, legibility, and contrast (178.3(a)(3)). Size of Markings- Unless otherwise specified the required UN Mark ings must be 6.0mm (.2 ") if the capacity is equal to or less than 30 kg (66 lbs) or 30 L (7.9 Gals.) and 12.0 mm (.47 ")ifthe capacity is more than 30 kg (66 lbs) or 30 L (7.9 Gals.) (178.3(a)(4)). Location of Markings- The required UN markings must be clearly visible and may not be marked on a "removeable head" (178.503(a) and 178.503(b)). 1. UN Indication- The package must be marked with the "UN Symbol'* (Brand), the letter "u" over the top of the letter "n" inside a circle. In lieu of the "UN Symbol'* just the letters UN are required on metal containers (receptacles) (49 CFR 178.503(a)(1)). 2. Packaging Identification Code- The Packaging Identification Code consists ofthe Type of Packaging, Material of Construction, and a Category within the type when applicable (178.503(a)(2). Table 1 below contains a summary ofthe most commonly used "Codes". The Type of Packaging will be indicated by an Arabic number such as the number 1 for a drum or the number 4 for a box (178.502(a)( 1)). The material that the packaging is constructed from will be indicated by an UPPER CASE Latin letter such as the letter A for steel or the letter G for Fiberboard. A UNIA is a steel drum (178.502(a)(2)). A (n) 4G is a Fiberboard box. In some cases such as barrels, drums, and jerricans, there is a number which indicates the category ofa container within a certain Type and Material. In marking drums and jerricans a "closed head" container would be indicated by the number 1 and an "open head" container would be indicated by the number 2 marked immediately after the Material of Construction Code. A drum marked UN1A1 would be a closed head steel drum and a drum marked UN1A2 would be an open head steel drum. Table 1-Type-Material-Category Tvoe 1 Drums 2 Barrels 3 Jerricans 4 Boxes 5 Bags 6 Composite Packagings 7 Pressure Receptacle Material A Steel B Aluminum C Natural Wood D Plywood F Reconstituted Wood G Fiberboard H Plastic L Textile M Paper, multiwall N Metal other than steel or aluminum P Glass Porcelain, or stoneware. Category A, Bf or H Drums-Jerricans 1 Closed Head 2 Open Head A or B Boxes 1 Ordinary A or B 2 A or B w/inner liner or coating C Boxes 1 Ordinary 2 w/sift proof walls H Boxes 1 Expanded Plastic 2. Solid Plastic LPags 2 Sift proof M Bags 2 Multi wall, water resistant Appendix 1-8 (0691) C 1991 GSI Cooqnrter Services Inc., Branson. MO. All rights resovod. ABDOO130754 a. Equivalent Packagings- The letter "W" after the Identification Code indicates that the packaging, although the sametype as that indicated by the code, is eithermanufactured or tested in a manner different than that specified in 178.505-178.523 or Subpart M of Part 178 under an approval issued by the Associate Administrator for Hazardous Materials Safety (178.503(a)(2)). b. Composite Packagings- When dealing with Composite Packagings two (2) letters are used, in sequence, for the Material Code. The first letter indicates the material ofthe inner receptacle and the 2nd indicates the material ofthe outer packaging. A UN6HA1 is a Composite Packaging consisting ofa plastic inner receptacle in a steel drum (178.502(b)). c. Combination Packagings- Only the codes for the outer packaging is used on combination packagings. The Inner Packagings may be metal, glass, etc. and there will be no indication oftheirtype or construction marked on the outside of the package (178.502(c)). 3. Performance Standard Code - An uppercase "X'*, "Y" or "Z" indicating the performance standard for which the packaging has been successfully tested as follows: X Meets Packing Group I, II, and III Y Meets Packing Group II, and III Z Meets Packing Group III only. Illustration: A box marked (^)4G/X should be a fiberboard box that has successfully passed the Packing Group I testing standards. A drum marked UN1A1/Y should be a closed head steel drum that has successfully passed the Packing Group II standards (178.503(a)(3)). 4. Designation of Relative Density (Specific Gravity) or Gross Mass - A number designating either the Specific Gravity or Gross Mass, as appropriate, for which the packaging has been successfully tested should come right after the Performance Standard Code as follows: a. Packagings without Inner Packagingsintended to contain liquids: Must be marked with the specific gravity rounded offto the first decimal place for which the packaging has been successfully tested. The Specific Gravity is not required when the Specific Gravity does not exceed 1.2. A drum marked UNI Al/ XI .4/ should be a closed head steel drum that has been successfully tested to Packing Group I standards for a Specific Gravity of up to 1.4. b. Packagings intended to contain solids or Inner packagings: Must be marked with the Maximum Gross Mass (Weight) in Kilograms for which the packaging has been successfully tested. A box marked (n) 4G/Y30/ should be a Fiberboard Box that has been tested to Packing Group II standards for a maximum Gross Weight of 30 kgs (66 lbs.). 5. Either an "S" or the Hydrostatic Test Pressure in kilopascals - An Upper Case S should be marked immediately after the Designation of Specific Gravity or Gross Mass, as appropriate, to designate that the packaging is intended only for solids or inner packagings. If the packaging is a single or composite packaging intended to contain liquids the Hydrostatic Test Pressure in kilopascals, (kPa) rounded offto the nearest lOkPaforwhichthepackaginghas been successfully tested must be marked in this sequence. Adrum marked UN1A1/X1.4/250/ should be a closed head steel drum that has been successfully tested to Packing Group I standards for a material that does not have a relative density of more than 1.4 and has successfully passed the Hydrostatic Pressure Test at 150 kilopascals (21.75 psi). A box marked (^j)4G/Y30/S/ should be fiberboard box, tested to Packing Group II standards with a Gross Weight of 30 kgs (66 lbs.) intended to contain either solids or inner packagings. Appendix 1-9 (0691) 01991 GSl Coo^uier Services Inc., BisaoD,MO. Ail rigba reserved. ABDOO130755 6. Last 2 Digits of the Year of Manufacture - The last two digits ofthe year during which the packaging was manufactured must be marked next in the sequence (178.503(a)(6)). A box marked G/Y3O/S/91 should be fiberboard box, tested to Packing Group II standards with a Gross Weight of30 kgs (60 lbs.) and intended to contain either solids g inner packagings which was manufactured in 1991. A drum marked UNI A1/X1.4/ 150/91 must be a closed head steel drum that has been successfully tested to Packing Group I for a material that does not have a relative density of more than 1.4, successfully passed the Hydrostatic Pressure Test at 150 kilopascals (22 psi), and which was manufactured in 1991. a. Type 1H and 3H Packagings- In addition certain plastic packagings such as the 1H1,1H2,3Hl,and3H2 must also be marked with the month that the packaging was manufactured which may be marked on the packaging in a place that is different from the remainder of the markings (178.503(a)(6)). Table 2- Illustrations of Common UN Markings UN1A1/Y/150/91 USA/+GS1234 A UN 1A1 closed head steel drum, tested to Packing Group 11 standards. No Relative Density entry is shown so it may only be used for materials with a realtive density not exceeding 1.2. The drum was tested under the Hydrostatic Pressure Test to 150 kilopascals (22 psi), was manufactured in 1991 and was marked under the authorization of the USA . The GSI is the symbol of the person authorizing the marking of the package with the UN markings and the numbers 1234, identify a particular packaging type or design. UN6HA1/Y1.4/250/91 USA/+GS1233 A UN6HA1 composite packaging, 6, consisting ofa plastic innerreceptacle, H, inside a closed head steel drum, Al. The packaging has been tested to Packing Group II standards, is suitable for materials with a Relative Density of up to ,1.4, was tested under the Hydrostatic Pressure Test to 250 kilopascals (36.26 psi), was manufactured in 1991, and was marked underthe authorization ofthe USA . The GSI is the symbol of the person authorizing the marking of the package with the UN markings and the numbers 1233, identify a particular packaging type or design. /Ti'N 4G/X30/S/91 \JTyUSA/+GS1232 A UN 4G Fiberboard box, tested to Packing Group I standards fora maximum Gross Weight of 30 kgs (60Lbs). It is intended only for Solids or inner packagings, was manufactured in 1991, marked underthe authority ofthe USA. The GSI is the symbol of the person authorizing the marking of the package with the UN markings and the numbers 1232, identify a particular packaging type or design. 7. The International Motor Vehicle Symbol - The International Motor Vehicle Symbol ofthe country under whose authoritythe testing and marking was done must be marked afterthe Year ofManufacture. Packagings tested and marked under the authority of the United States, must be marked with the letters USA (178.503(a)(7)). For packagings tested and marked under the authority of another country this mark is the International Motor Vehicle Symbol ofthe country under whose authority the testing and marking was done, such as, CAN for Canada, F for France, D for Germany, GB for Great Britain, IL for Israel, J for Japan, NL for Holland orthe Netherlands, and SU forthe Soviet Union. The markings USA as shown in Table 2 above illustrate this marking. Appendix I-10 (0691) 01991 GSI Computer Services Inc., Branson, MO, All rights reserved. ABDOO130756 8. Identification ofManufacturer or Other Identification - Eitherthe name ofthe manufacturer or some other identification of the packaging specified by the appropriate national authority must be marked on the packaging after the International Motor Vehicle Symbol. Packagings tested and marked under the authority ofthe United States must be marked with either the Name and Address or symbol ofthe person applying the UN packaging specification markings to the packaging. Ifa symbol is used it must be registered in advance with the Associate Administrator ofHazardous Materials Safety (RSPA). The markings ofthe symbol +GS as shown in Table 2 on Page 1-13 illustrate this marking. Packagings that have been tested and certified by an Approval and Certification Agency certified by DOT in accordance with Subpait E of Part 107 of 49 CFR may meet this requirement by marking the Registered Symbol ofthe Certifying Agency. In addition some unique form of identification will normally follow the symbol ofthe Certifying Agency to identify a particular packaging type and certification. A UNIA1 steel drum marked as shown in Figure 2 on Page 1-13 indicates that someone with the registered symbol +GS has certified that the drum meets all applicable UN packaging requirements. Questions involved with the compliance of this packaging with applicable packaging regulations would more than likely be resolved through contact with the organization to whom the symbol +GS is registered and, in this case, would center around their particular Approval or Certification #1234 to see whether or not the package as offered for shipment was the same type and design as that certified by the Certification or Approval Agency. 9. Metal or Plastic Drums/Jerricans Intended to be Reconditioned: Metal orplastic drums which are intended for reuse as either single packagings or as an outer packaging for a Composite Packaging must have the minimum thickness of the material, shown in millimeters and abbreviated mm as the last item in this sequence, as illustrated below (178.503(a)(10)): UN1A1/Y/150/91 USA/+GS1234 1 mm 10. Reconditioned Packagings - Packages that have been reconditioned must be marked with the following additional marks near the other required specification packaging-marks (178.503(c)): a. The name or symbol of the country in which the reconditioning was performed. Use USA for packag ings reconditioned in the USA; and b. The name and address or registered symbol of the reconditioner. If a symbol is used it must be registered in advance with the Associate Administrator for Hazardous Materials Safety; and c. The month and last two (2) digits ofthe year of reconditioning such as 11-91; and d. The letter R; and e. The letter L_i the packaging successfully passed a leakproofness test as part of the reconditioning process. - Illustration: A UN1A1 steel drum marked as indicated below indicates that it has been reconditioned by a reconditioner with the symbol RB, in the United States, as indicated by the code USA, during October of 1991, as shown by the 10-91. The letter R indicates that it is a reconditioned drum and the letter L that the drum has successfully passed the leakproofness test. UN1A1/Y1.4/150/90 USA/NS1234 1 mm USA/RB/10-91RL Appendix 1-11 (0691) 01991 GSI Compute Services Inc., Brinson, MO. All rights reserved. ABDOO130757 INTRODUCTION TO GSI'S TRANSPORTATION EMERGENCY RESPONSE INFORMATION MANAGEMENT SYSTEM (TERIMS) By: Gary J. Groman, BSBA, JD EMERGENCY RESPONSE INFORMATION WITHIN THE TRANSPORTATION SYSTEM UNDER SUBPART G OF 49 CFR New Emergency Response Liability for Shippers The third publishing of HM-126C "Emergency Response Communication Standards'*, by the Research and Special Programs Administration (RSPA), is contained in the August 17, 1990 Federal Register starting at page 33707. Except as noted immediately following, the effective date of HM-126C has been delayed until December 31, 1990. The effective date for the requirement to mark the Technical Name on non bulk packagings filled for shipment prior to December 31. 1990 has been delayed until December 31, 1991. Although not mandatory until the dates indicated above immediate compliance is authorized. When the new Emergency Response Information requirements become effective, shippers of Hazardous Materials will be required to ensure that "Emergency Response information conforming to the requirements of this Subpart (Subpart G ofPart 172 of49 CFR) is immediately available for use nt all time*; the hazardous material is present." (172 600(c)(1)). It must be specific Emergency Response information "that can be used in the mitigation of an incident involving Hazardous Materials" (172.602(a)). The Emergency Response Information requirements of the new Subpart G leaves shippers in a very vulnerable enforcement and liability position in the event of an accident or incident involving the transportation of their Hazardous Materials. This liability is further expanded by the general way the requirements are stated in this Subpart. Words such as "at a minimum" and "comprehensive" are not exactly words of limitation. In addition DOT (RSPA) has used wording in the "Preamble" to the Final Rule Making for HM-126C indicating that the Final Rule is "intended to provide specific information relative to the hazards of the material being transported..." and later in the same paragraph states "This information may be in any format......so long as that document provides information, which at a minimum, provides.......... " (Federal Register, June 27, 1989, page 27142). Maximum Shipper Liability vs Minimum Carrier Liability When the actual regulatory wording and information in the Preamble to HM-126C are considered together it does not take a legal Solomon to realize that it is the primary responsibility of the person offering the Hazardous Material for transportation (the Shipper) to supply specific Emergency Response information relative to the Hazardous Material being transported. Although there is a requirement on the part of the Carrier to ensure that the information is immediately available, the Carrier has little more liability than they have currently. Why? It is the Shipper's responsibility to either present the Carrier with the specific information required by 172.602(a) or ensure that in fact such information is immediately available at the time the Hazardous Material is Offered for transportation (172.602(c)). In addition, it is the Shipper's responsibility to furnish the Emergency Response Telephone Numbers) on the Shipping Paper as required by 172.604(a). The accuracy and suitability of the information provided is the responsibility of the Shipper. The Carrier's very limited liability consists of insuring that the Emergency Response information that was immediately available at the time the Hazardous Materials were offered for transportation is carried as required by 172.602(c)(1) and is made immediately available to Emergency Response or other appropriate personnel responding to "an incident involving a (the) Hazardous Material, or (is) conducting an investiga tion which involves a Hazardous Material" (172.600(c)(2). Whether or not the information is specific enough for the material being shipped or provides the minimum information, the major real liability associated with these new regulations, is the responsibility of the Shipper. Appendix II- 1 (069i) O 1991 GSI Computer Services Inc., Branson, MO <5616 Reprinted with pcnmuton. All rights reserved. ABDOO130758 How GSI's Transportation Emergency Response Information Management System (TERIMS) Can Help Ensure Regulatory Compliance GSI's Transportation Emergency Response Information Management System (TERIMS) provides an efficient and simple way to not only meet the regulatory requirements of both 172.602 and 172.604 but to enhance the safety involved with the transportation of Hazardous Materials within the transportation system by providing: 1. State ofthe art computer access to the information contained in the U.S. DOT'S Emergency Response Guidebook (ERG). 2. The ability to develop and manage efficiently, Customized Emergency Response information on the products your company offers or accepts for transportation. This information may be based wholly or in part on the information contained within the DOT ERG, created separately, or be a combination of both. It may be incorporated directly from the U.S. DOT ERG portion of TERIMS without retyping and used as is or modified as appropriate to develop Emergency Response Information that is specific for the products and/or Hazardous Wastes you offer for transportation within the transportation system. 3. Provides the Initial Emergency Response Information required by 172.602(a) that can be as general or as product specific as needed to ensure regulatory compliance and do it in a simple efficient manner. 4. A convenient way to gather and manage the comprehensive Emergency Response Information required to be available when Emergency Responders call the telephone number required by 172.604(a). Once entered into TERIMS it can be used directly by those in your organization to meet the requirements of 172.604(a) or printed out and provided to those agencies and organiza tions that agree to provide that information for us as permitted by 172.604(b). 5. An efficient method of storage, retrieval, and utilization of all transportation related Emergency Response Information using state of the art technology to access and use the information as needed. Detailed Discussion of Subpart G to Part 172 of 49 CFR The rest of this page through page 6 contains a more detailed discussion of the requirements for the Emergency Response information contained within Subpart G of Part 172. GSI's Transportation Emergency Response Information Management System (TERIMS) is an IBM PC Program designed to to ensure regulatory compliance, enhance safety, and reduce your organization's exposure to the civil liability that can accrue as a result of the failure to comply with the regulatory requirements of this Subpart G. Readers of this book can obtain a free demo disk of this program by calling 1-417-334-7071. TWO DIFFERENT TYPES OF INFORMATION REQUIRED In general Subpart G of 49 CFR requires two (2) different types of Emergency Response Information. The First is what we call the "Minimum Initial Responder Information'' which must be immediately available either on or in association with the Shipping Papers at all times when Hazardous Materials are present (172.602). The Second is the comprehensive product specific Emergency Response information which must be immediately available from a person who is contacted through a Shipper provided Emergency Response telephone number listed on the Shipping Paper (172.604). First Type Minimum Initial Responder Information (172.602) This information will assist the Initial Responder at the scene ofan accident or incident and as "a minimum", in addition to the information required to be on the Shipping Paper by 172.202 and 172.203, "must contain information** on "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, initial methods for handling spills, or leaks in the absence of fire, and preliminary first aid measures'* (172.602(a)). Appendix II- 2 (069i) O 1991 GSI Congnter Savicet lac., Branson, MO 6$616 Reprinted witb pandaston. All rights reserved. r ABDOO130759 How is it Provided The required Emergency Response Information must be printed legibly in English and be available for use away from the package containing the Hazardous Material it relates to (172.602(b)(l)-(2)). It may be presented in one of three (3) ways: 1. "On a Shipping Paper" (172.602(b)(3)(i)) or, 2. In a document other than a Shipping Paper "providing the Basic Description and Technical Names are on the document as required by 172.202 and 172.203(k)" (172.602(b)(3)(ii) or, 3. "Related to the information on a Shipping Paper .... in a separate document... in a manner that cross references the description of the Hazardous Material on the Shipping Paper with the Emergency Response information contained in the document" (172.602(b)(3)(iii)). Method #1, putting the information on the Shipping Paper, is not practical in most situations because it will result in voluminous Shipping Papers with Emergency Response information between each entry. Method #2, using a separate document and providing the Basic Description and Technical Names as required by 172.202 and 172.203(k), is restrictive and, in our opinion, is best used , if at all, in those situations where the Technical Name(s) is not required by 172.203(k). When various Hazardous Materials are shipped on the same Shipping Paper using a generic Proper Shipping Name such as Flammable liquid, n.o.s. Method #2 is not very practical because of the requirement to include the Technical Name(s). This could result in 10 separate Emergency Response documents containing Emergency Response Information for one (1) Shipping Paper describing 10 different Flammable liquid, n.o.s. Hazardous Materials each requiring different Technical Name entries under 172.203(k). Least Restrictive With Most Flexibility Of these three (3) choices we at GSI believe that Method #3 provides the most efficient and flexible method for Shipper compliance. It permits the use of a separate document to provide the Emergency Response information providing the information is "related to the information on the Shipping Paper." Such a relationship may be established by including the Proper Shipping Name or ID Number on the separate document. It does not require the inclusion ofthe Technical Name and in this writer's opinion, provides much more flexibility than that provided in 172.602(b)(3)(ii). One (1) such document containing the required Emergency Response Information, the Proper Shipping Name Flammable liquid, n.o.s and the ID Number UN1993 could cover one (1) Shipping Paper describing 10 different Flammable liquid, n.o.s. Hazardous Materials requiring different Technical Name entries providing the Emergency Response Information on the document was applicafale_to_each. The relationship between the document and the Shipping Paper is established by the Proper Shipping Name Flammable liquid, n.o.s and the ID Number UN1993. Although this method will most commonly be used in conjunction with the use of Emergency Response Guidance Documents such as the D.O.T. Emergency Response Guide Book (ERG), its use is permitted for any document that provides the required cross referencing and is not limited to the ERG or similar type documents (172.602(b)(3)(iii)). Second Type Comprehensive Product Specific Emergency Response Information (172.604) The comprehensive product specific Emergency Response incident mitigation information required by 172.604(a) must be furnished by each person who offers a Hazardous Material for transportation through a 24 hour Emergency Response telephone number. This telephone number must be: 1. Monitored at all times the Hazardous Material is in the transportation system including incidental storage bv a person who is either a. Knowledgeable of the hazards and characteristics of the Hazardous Material being shipped and has comprehensive Emergency Response and incident mitigation information or b. Has immediate access to a person who has such knowledge and information and Appendix II- 3 (069i) O 1991 GSI Computer Services Inc., Brinson, MO 65616 Reprinted with permission. All righa reserved. 1 ABDOO130760 2. Entered on the Shipping Paper as follows: a. Immediately following the description of each Hazardous Material required by 172.202 and 172.203 or b. Once in a clearly visible location on the Shipping Paper if (1). The number is applicable to each Hazardous Material on the Shipping Paper and (2). Contains an indication that it is for Emergency Response information purposes. We at GSI recommend prefacing the number with the wording EMERGENCY CONTACT or similar wording such as Emergency Response Number etc. Use ofAnother Agency or Organization The person offering the Hazardous Material for transportation may use the telephone number of another agency or organization capable of providing the detailed information concerning the Hazardous Material i 1. That agency or organization has accepted the responsibility for providing that information in accordance with the requirements of 172.604(a) and 2. The person offering the Hazardous Material for transportation has ensured that the agency or organization acting on their behalf has received current information on the hazards and character istics of the Hflrardous Material being shipped and the comprehensive Emergency Response and incident mitigation information for that material meeting the requirements of 172.604(a)(2), before the Hazardous Material is offered for transportation (172.604(b)). CHEMTREC and 172.604 CHEMTREC is, in this author's opinion, the premier provider of Emergency Response information to Emergency Responders in the event ofan accident or incident involving the transportation of Hazardous Materials. It is his further opinion however, that registration with CHEMTREC under their current system does not relieve the Shipper from the 172.604(a) responsibility to have a person immediately available at the telephone number furnished to CHEMTREC, at the time of registration, with the comprehensive product specific Emergency Response and incident mitigation information for the particular material being shipped. In terms of 172.604 CHEMTREC is acting as an answering and referral service and it is up to the shipper to make sure that the information required by 172.604(a)(2) is immediately available when CHEMTREC calls in the event of an Emergency Response request for this information. Get It In Writing In using another agency or organization, CHEMTREC or otherwise, as authorized in 172.604(b) to meet your responsibilities under 172.604(a) we at GSI recommend that, at a minimum, the person offering the Hazardous Material for transportation: 1. Keep acopy of the "comprehensive emergency response and incident mitigation information" for the particular material being shipped that was sent to that organization, and 2. Get a written dated acknowledgement from that organization that: a. It has received that information and b. They accept the "responsibility for providing the detailed information concerning the Hazardous Material as required by 172.604(a) and c. Will hold your organization harmless from any enforcement or civil liability resulting from their failure to furnish such information as required. IT REQUIRES SOME THOUGHT The providing of the Emergency Response information required by Subpart G of Part 172 is not as simple as saying "We will use the ERG" or, "Our MSDSs are OK", or "We'll require the Carrier to have an ERG on the vehicle." When considering how we are going to meet the requirements of this paragraph it should be remembered that although DOT cites the MSDS and Emergency Guidance manuals Appendix II- 4 (069i) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130761 possible wavs to meet the requirements ofSubpart G, it in no way authorizes their use as an automatic means of compliance with either 172.602 or 172.604 if they do not meet all the applicable requirements of those Sections. Use ofMSDS Under 172.602 In the preamble to HM-126C RSPA points out that it "has not required nor prohibited the use ofMSDS as a means of providing the information... ". Later in the same paragraph RSPA points out "However as has been made evident in the course of this rule making action, (that) no single standard exists for the preparation of MSDSs to provide emergency response information for transportation incidents....the MSDS mav not, in all instances, provide specific information relative to response actions to be taken during transportation related incidents (Federal Register, June 27, 1989, page 27142). The experience of this author in dealing with MSDS information is consistent with the RSPA's findings, particularly, as relates to transportation related incidents and accidents. May the MSDS be used to meet the requirements of 172.602(a)? Yes. Is an MSDS blessed with automatic compliance with the requirements of 172.602(a)? No! Although an MSDS may be used it must contain the specific information required in 172.602(a). On July 25, 1990 GSI Inc. received a written interpretation from RSPA stating that the use of an MSDS not containing the specific information required by 172.602(a) does not constitute compliance with 172.602(a). If the MSDS is going to be used to meet the requirements of 172.602(a), we at GSI recommend that the user ensure that, at a minimum, it contains the specific items ofinformation required by 172.602(a). We further recommend that steps be taken to provide the information in one place on the MSDS in a manner that is readily accessible and understandable to Emergency Response Personnel, i.e. Don't make them hunt through 14 pages of information to get what they need Use ofMSDS Under 172.604 May the MSDS be used to meet the requirements of 172.604(a)? Using the same rationale as above the answer is a qualified "Yes". Is an MSDS blessed with automatic compliance with the requirements of 172.604(a)? No! Although an MSDS may be used, if it is, it must contain specific information about the "hazards and characteristics of the Hazardous Material being shipped" and "comprehensive emergency response and incident mitigation information" for that Hazardous Material. It is this author's opinion that it is very unlikely that an MSDS for a particular product would meet the requirements of 172.604(a)(2) unless it had been specifically designed to contain the information required by that paragraph. On July 25, 1990 GSI Inc. received a written interpretation from RSPA stating that the use of an MSDS not containing the specific information required by 172.604(a)(2) does not constitute compliance with 172.604(a)(2). But CHEMTREC Requires an MSDS for Registration In a conversation with Mr. Mike Donahue of CHEMTREC on July 31, 1990 he informed this writer that CHEMTREC's requirements for the MSDS was a CHEMTREC requirement for registration and that the mere submission of the MSDS by those registering with CHEMTREC was not intended to be compliance with 172.604(a). He further stated that they were receiving thousands of MSDSs and that no one at CHEMTREC was checking them to see if they contained any of the information required bv 172.604(aY21 let alone to see ifit was accurate. He stressed that the compliance with 172.604(a) would be achieved, inmost cases, by the organization registering with CHEMTREC, through the Emergency Response Contact Person and Telephone Number that is part of the Registration. Use of the Emergency Response Guide (ERG) Under 172.602 No One Method Required The Preamble to the Final Rule Making states "RSPA (DOT) has not imposed a requirement that the ERG be carried on each transport vehicle and be maintained at facilities involved with the transportation of Hazardous Materials. Rather the Final Rule requires that specific emergency response information accompany shipments of hazardous Materials and be present at transportation facilities." Earlier in the same paragraph RSPA states that the Final Rule is "intended to provide specific information relative to the hay-arris of the material being transported.... " Later, in the same paragraph, RSPA states Appendix II- 5 (069i) O 1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with permission. All rights reserved- ABDOO130762 "This information may be in any format......so long as that document provides information, which at a minimum, provides the description of the Hazardous Material, immediate health hazard information, risks of fire and explosion, immediate precautions to be taken in the event of an accident or incident, immediate methods of handling large and small fires, initial methods for handling of spills or leaks, and preliminary first aid measures'* (Federal Register, June 27, 1989, page 27142). Does Use of ERG Ensure Compliance? Maybe! Can the ERG be used to meet the requirements of 172.602(a)? Yes. Is the ERG blessed with automatic compliance with the requirements of 172.602(a)? The answer to that question is not as easy as at first seems. That's right folks, even though millions of ERGs will be printed and sold_allegedly to ensure compliance with the provisions of 172.602(a) the answer has to be a qualified maybe. On the July 25, 1990 GSI Inc. received a written interpretation from RSPA stating that the use of the ERG is "one option available that may be used to comply with the requirements of 172.602(a). Further, in the same interpretation, in response to the question: "Does the sending of a letter or contractual provision between the shipper and carrier, requiring carriers to have copies of the ERG aboard their vehicles, relieve the shipper from any further responsibility to ensure that the information required by 172.602(a) is immediately available at the time the Hazardous Material is offered for transportation?" RSPA replied: "The answer is no. Section (paragraph) 172.600(c) states that no person may offer, accept, or transport hazardous materials unless the required emergency response information is available for use at all times. Therefore, if a person offers hazardous materials to a carrier and the required emergency response information is not present, the offerer would be in violation of these requirements. We believe this objective is similar to the one addressed by 172.506, which requires a person offering a Hazardous Material for transportation to provide the required placards to a motor carrier, unless the motor vehicle is already placarded as required." Based on the above RSPA permits the use of the ERG but does not require its use. In addition, if used, the person offering the Hazardous Material for transportation must ensure that the ERG being used is "maintained as specified." It is this author's opinion, based on the wording in 172.602(c) and the above cited interpretation, this would include at a minimum, checking the ERG to ensure that information required by 172.602(a) is in fact in the ERG at the time the Hazardous Material is offered for transportation. If The ERG Is Used If the ERG is used for compliance with 172.602(a) we at GSI recommend the following: 1. Have some basis for stating that the information provided through the use of the ERG is appropriate for the specific Hazardous Material being offered for transportation, and 2. Check the copy of the ERG being used, whether shipper or carrier furnished, to make sure that it has the Yellow, Blue, Orange, and Green bordered pages, if applicable, that apply to each specific Hazardous Material being offered for transportation. Civil Liability Although from a pure enforcement point of view, based on some wording in the Preamble this writer could make a semi effective argument that use ofthe ERG constitutes compliance with the provisions of 172.602(a), that argument would hold very little water as to an organization's civil liability. In this writer's opinion RSPA has created a new area of job security for the legal profession through the expanded liability created in the wording in 172.602 itself and the Preamble to the Rule Making. It is his further opinion that the pure rote utilization of the ERG without making sure that the resulting Guide Page covers the hazards of and provides the required 172.602(a) information for the particular Hazardous Material being transported, exposes the person offering the Hazardous Material for transportation to increased civil liability. In this regard he is not alone. Mr. Gordon Rousseau, in his excellent article in the May/June issue of The Chemical Packaging Review entitled "Emergency Response- A New Liability" states Appendix II- 6 (069i) O 1991 GSI Computer Service* Inc., Branson, MO 6S616 Reprinted with permission. All rights reserved. ABDOO130763 "Many have been misled by DOT'S frequent reiterations about the use ofthe ERG as a potentially satisfactory document. They may have stopped reading or thinking too early. From a liability perspective the ERG page clearly is not an automatically adequate solution.'' To that this writer would add "Amen." TERIMS Can Help Ensure Regulatory Compliance and Limit Civil Liability We believe that GSI's Transportation Emergency Response Information Management System (TERIMS) provides an efficient and simple way to meet the regulatory requirements of both 172.602 and 172.604; limit the civil liability of your company or organization; and enhance the safety involved with the transportation of Hazardous Materials within the transportation system. Further the use of TERIMS to print the Emergency Response information required by 172.602(a) will ensure that in fact the information furnished at the time the Hazardous Materials are offered for transportation is as specific and current as desired, was in fact provided, and eliminate the need to inspect a copy of the ERG to see that all the required pages are present for each Hazardous Material offered for transportation. Readers of this book can obtain a free demo disk of this program by calling 1-417-334-7071. Appendix II- 7 (0691) O 199) GS1 Computer Service* lac., Branson, MO 65616 Reprinted with permission. All rights reserved. ABDOO130764 APPROVED THIRD-PARTY PACKAGING CERTIFICATION AGENCIES The following third-party packaging certification agencies have been approved by the Department of Transportation to certify conformance of packagings with UN standards pursuant to 49 CFR; Part 107, Subpart E as of June of 1991. For ease of use the list is sorted Alphabetically bv State. Wyle Laboratories 7800 Governor's Drive West P.O. Box 077777 Huntsville, AL 35807 205- 837-4411 Charles E. Tudor CP-P/MH 3869 Mammoth Cave Court Pleasanton, CA 94588 415- 462-4493 Lansmont Corporation Ryan Ranch Research Park 5 Harris Court Bldg. N Monterey. CA 93940 408-373-3800 Wyle Laboratories 1841 Hillside Avenue Norco, CA 91760 714- 737-0871 Package Design & Testing Corp. ofNew England 10 Hazelwood Road East Granby, CT 06026 203- 653-8086 Park City Packaging, Inc. 490 Sniffen Lane Stratford, CT 06497 203- 378-7384 Smurfit Plastic Packaging, Inc. 1204 East 12th Street Wilmington, DE 19802 302- 573-2581 Stone Container Corp. P.O. Box 105 Contonment, FL 32533 904-968-5414 Yowell International 7805 Ellis Road Melbourne, FL 32940 407- 725-3611 Construction Technology Laboratories, Inc. 5420 Old Orchard Road Skokie, IL 60077 708- 965-7500 Container-Quinn Testing Labs. 170 Shepard Ave. Wheeling, IL 60090 708 537-9470 Gaynes Testing Laboratories, Inc. 1642-52 West Fulton Street Chicago, IL 60612 312- 421-5257 Pro-Pack Testing Laboratory, Inc 15 N. Florida Belleville, IL 62221 618 277-1163 Jefferson-Smurfit Corporation & Container Corp. of America 450 East North Ave. Carol Stream, IL 61088-2195 708- 260-3590 Westinghouse Elec. Corp. ISLD 111 Schilling Road, MS 7980 Hunt Valley, MD 21030 301-584-5368 Hedwin Corporation 1600 Roland Heights Avenue Baltimore, MD 21211 301-467-8209 Ext. 312 Appendix III- 1 (0691) ABDOO130765 Distribution Dynamics Labs. Inc. 14958 Martin Drive Eden Prairie, MN 55344 612- 937-4746 TEN-E Packaging Services 3670 Dodd Road Eagan, MN 55123 612- 683-0063 Ecolab, Inc. 940 Lone Oak Road Eagan, MN 55121 612-452-1460 Package Research Laboratory 41 Pine Street Rockaway, NJ 07866 201 627-4400 Union Camp P.O. Box 3301 Princeton, NJ 08543 609- 986-1200 Union Carbide Corporation P.O. Box 670 Bound Brook, NJ 08805 201-563-5000 United States Testing Company, Inc. 1415 Park Avenue, Hoboken, NJ 07030 201-575-5252 Container Testing Laboratory, Inc. 607 Fayette Avenue Mamaroneck, NY 10543 914-381-2600 Georgia Pacific 1660 Indian Wood Circle Maumee, OH 43537 419- 891-5963 GH Package-Product Testing & Consulting, Inc. 11301 Jefferson Avenue Sharonville, OH 45241 513- 733-8378 Owens - Illinois One Seagate-25-L-GC Toledo, OH 43666 419- 247-7424 Delvalco Consultants 2 McKinley Avenue Malvern, PA 19355 215- 644-9117 Pro Pack Inc. 76 Jansen Avenue Essington, PA 19029 215-521-4050 RVR Package Testing Center 1702 Taylor Street Houston, TX 77007 713- 861-8221 Appendix III- 2 (0691) l1^ department of portation Research and Special Programs Administration ABDOO130766 DOT CHART 9 Hazardous Materials Marking, Labeling & Placarding Guide This Marking, Labeling and Placarding Guide will assist shippers, carriers, fire departments, police, emergency response personnel, and others in complying with, and enforcing the regu lations governing the safe transport of hazardous materials by highway, rail, water and air. The information and illustrations presented in this Guide are intended to serve as an in troduction to regulations governing hazardous materials transportation. The Guide should be read in conjunction with the Hazardous Materials Regulations (HMR; 49 CFR 100-199). Published annually, and amended periodically, the HMR are the key to compliance and contain the information needed to comply with the requirements for the safe transport of hazardous materials. Hazardous materials markings, labels, placards, and shipping papers serve to com municate the hazards posed by materials in transportation. Hazard communication is the key to effective emergency response, and is also used to alert transportation work ers and the general public of the presence of hazardous materials, insure that noncompatible materials are not loaded together in the same transport vehicle, and pro vide the necessary information for reporting hazardous materials incidents. The purpose of this Guide is to explain and identify the markings, labels and placards which appear on packages, freight containers and transport vehicles containing hazardous materials. Marking regulations (Section 172.300) require information, specific to the ' azardous material, to be `'marked" on the outside of the package. Examples of ) information required to be marked on the package are the proper shipping ,,ame, identification number and consignor's or consignee's name. For how markings required by the HMR are to be applied to a package, see Section 172.304. For exceptions to the marking requirements and additional marking requirements, see Section 172.300. This chart does not attempt to cover all the marking requirements. In particular this chart does not contain any infor mation related to specification packaging markings addressed in the Parts 178 and 179 of 49 CFR. For further details on required markings, consult the appropriate sections in the HMR. The Labeling of a package of hazardous material is specific to the hazard class of the material. The Hazardous Material Tables, Section 172.101 and 172.102, identify the proper label(s) for the hazardous ma terial listed. In some cases, a hazardous material will meet the defini tion of two or more hazard classes. In these instances, the additional labeling requirements of Section 172.402 must be met. Labels, when required, must be placed next to the marked proper shipping name (Section 172.406). The requirements for labels can be found in Sec tion 172.400-172.450. Placards represent the hazard class(es) of the material(s) con tained within the freight container, motor vehicle or rail car. The requirements for placarding are contained in Section 172.500172.558. NOTE: This document is for general guidance only and is not a substitute for the requirements of 49 CFR 100-199. Response begins with identification. transport vehicle carrying 1 package of dioactive Material labeled Yellow III, pounds of Flammable Liquid and 600 pounds of Corrosive Materials would be placarded with both RADIOACTIVE and DANGEROUS placards. Hazardous Materials Warning Labels DOMESTIC LABELING General Guidelines on Use of Labels (CFR, Title 49, Transportation, Parts 100-177) Labels illustrated above are normally for domestic shipments. However, some air carriers may require the use of International Civil Aviation Organization (ICAO) labels. Domestic Warning Labels may display UN Class Number, Division Number (and Compatibility Group for Explosives only) [Sec. 172.407(g)). Any person who offers a hazardous material for transportation MUST label the package, if required [Sec. 172.400(a)). The Hazardous Materials Tables, Sec. 172.101 and 172.102, iden tify the proper label(s) for the hazardous materials listed. Label(s), when required, must be printed on or affixed to the sur face of the package near the proper shipping name (Sec. 172.406(a)). When two or more different labels are required, display them nex to each other (Sec. 172.406(c)). Labels may be affixed to packages (even when not required by regulations) provided each label represents a hazard of the mater ial in the package [Sec. 172.401). Check the Appropriate Regulations Domestic or international Shipment Additional Markings and Labels Poisonous Materials HAN0UNG LABELS Cargo Aircraft Only 172.402(D) < M 1 ION Bung LaDel 172.402(e) ORM-E 172.316 INNER PACKAGES COMPLY WITH PRESCRIBED 173 25(a)(4) 172.312(a)(c) Package Orientation Markings ____ --____ --ZZZ'ZL'Z Fumigation 173.9 EMPTY 173.427 Here are a few additional markings and labels pertaining to the transport of haz ardous materials. The section number shown with each item refers to the appro priate section in the HMR. The Hazardous Materials Tables. Section 172.101 and 172.102. identify the proper shipping name, hazard class, identification num ber, required labe!(s) and packaging sections. Materials which meet the inhalation toxicity criteria specified in Section I73.3a(b)(2), have aaaitional "communication standards prescribed by the HMR First, the words 'Poison-lnnaiation Hazard must oe entered on the shipping paper, as required by Sec tion 172.203(k){4), tor any primary capacity units with a capacity greater than one liter Second, pack ages of 110 gallons or less capacity must be marked "Inhalation Hazard" in accordance with Section 172.301(a). Lastly, transport vehicles, freight contain ers and portable tanks subiect to the shipping pap requirements contained in Section 172 203(k)(4) must be placarded with POISON placards m addn. to the placards required by Section 172 504 For ad ditional information and exceptions to these commu nication requirements, see the referenced sections in the HMR. of the DOT Emergency Response Guidebook handy! Hazardous Materials Warning Placards DOMESTIC PLACARDING Illustration numbers m each square refer to Tables t and 2 below. A 0 k^xplosiveK (^WLOSIVB^ Ablastihg\ / poison\ J?X 8 X AGENTS \ GAS / \\2/ A\ /A d "/tv Coxwto 4flammabl^> <MAMMABLK> \l SOLID / \IZ 0 <CHL0RINE> y/ #DRGANICX \PEROXIDILX <P0IS0N> Radioactive)) \6 // RangerouX WHITE SQUARE BACKGROUND FOR PLACARD HIGHWAY Used for ' HIGHWAY ROUTE CONTROLLED QUANTITY OF RADIOACTIVE MATERIALS." (Sec 172.507) RAIL Used for RAIL SHIPMENTS 'EXPLOSIVE A. 'POISON GAS" and "POISON GAS RESIDUE placards (Sec. 172.510(a)) | i Guidelines (CFR. Title 49, Transportation, Parts 100-177) Placard any transport vehicle freight container, or rail car containing any quantity of material listed in Table i Materials which are shipped m portable tanks, cargo tanks, or tank cars must oe placarded when they contain any quantity oi Taole i and'or Table 2 material Motor vehicles or Ireighl containers containing packages which are subject to the Poison-Inhalation Hazard shipping paper description oi Section 172 203(k)(4), must be placarded POISON in addition to the placards re quired by Section 172 504 (see Section 172 505) When the gross weight ol all hazardous material covered m TABLE 2 is less than 1000 pounds, no placard is required on a transport vehicle or treighi container Placard freight containers 640 cubic feet or more containing any quantity ot hazardous material classes listed in TABLES i and/or 2 when offered for transportalion by air or water (see Section 172 512(a)) Under 640 cubic feet see Section 172 512(b) TABLE 1 Hazard Classes Class A explosives No. t Class B explosives 2 Poison A 4 Flammable solid (DANGEROUS WHEN WET label only) 12 Radioactive material (YELLOW III label) 16 Radioactive material Uranium hexafluoride fissile (Containing more than jOoU235) ISA 17 Uranium hexafluoride, low-specific activity (Containing t 0o or lessU235) 16 & 17 Note For details on me use ot Tables 1 and 2. see Sec 172 504 (see foot notes at bottom of fables ) TABLE 2 Hazard Classes Class C explosives Blasting agent Nonflammable gas Nonflammable gas (Chlorine) Nonflammable gas (Fluorine) Nonflammable gas (Oxygen, cryogenic liquid) Flammable gas Combustible liquid Flammable liquid Flammable solid Oxidizer Organic peroxide Poison B Corrosive material Irritating material No. 18 3 15 10 9 11 13 14 15 17 13 UN or NA Identification Numbers PLACARDS OR ORANGE PANELS 1 1090 Appropriate Placard must Oe used MUST BE DISPLAYED ON TANK CARS. CARGO TANKS. PORTABLE TANKS AND BULK PACKAGINGS When hazardous materials are transported m Tank Cars (Section 172 330). Cargo Tanks (Section J72 328), Ponaole Tanks (Section 172.326) or Bulk Packagmgs (Section 172 331 >. UN or NA numbers must be displayed on placards orange panels or. wnen authorized plain white square-on-pomt config uration UN (United Nations) or NA (Norm American) numbers are found m me Hazardous Materials Tables. Sections 172 101 and 172 102 Identification numbers may not be displayed on POISON GAS. RADIOACTIVE, or EXPLOSIVE A. EXPLOSIVE B.' BLASTING AGENTS, or DANGEROUS placards (See Section 172 334 j In lieu ol the orange panel, identification numoers may be placed on plain wnne square-on-pomt con figuration wnen mere is no placard specified for the hazard class (e g.. ORM-A. B. C. D or E) or where the identification number may not oe displayed on me placard See Section 172 336(b) for ad ditional provisions and specifications When the identification number is displayed on a placard me UN Hazard class number must oe dis played in the lower corner of each placard (see Section 172 332 (c)(3)) Specifications of size and color of the Orange Panel can oe tound m Section 172 332(0) NA numbers are used only in the USA and Canada Additional Placarding Guidelines A transport venicle or freight container containing two or more classes of material requiring different placards specified m Table 2 may be ptacarceo DANGEROUS in place of the separate placards specified for each of those classes of material spe cified m Taole 2 However, wnen 5000 pounds or more of one class of material is loaded therein at one loading facility, the placard specified for that class must be applied This exception oroviceo >n Section 172 504(b), does not apply to ponaole tanks tank cars, or cargo tanks CAUTION: Check eacn shipment for comoliance with me approbnate Hazardous materials regula tions -- Proper Classification Packaging. Marking Labeling, Placarding. Documentation -- prior to offering for smpment In an emergency, call Chemtrec. 1-800-424-9300 Examples of Canadian and International Placards and Labels The shipment of hazardous materials internationally is governed by one or more regulatory bodies with regulations that may be similar to domestic regulations or radically different. Canada, for example, has adopted wordless placards and labels because their country is bilingual. Canada also requires cargo and rail tanks to use retroreflective placarding. However, Canada and the United States have reciprocity regarding the use of wordless and worded placards and labels. Several international organizations govern the transportation of hazardous materials according to the mode of transportation. If a shipment is going by water, the International Maritime Organization (IMQ) has authority. The International Civil Aviation Organization (ICAO) is concerned about the safe shipment of dangerous goods (i.e.. hazardous materials) by air. Transport Canada (TC) is the Canadian counterpart to the U.S. Department of Transportation (DOT). The United Nations publishes "Recommendations for the Trans port of Dangerous Goods," a publication that is used by many na tions of the world when promulgating regulations. Since the safe transport of hazardous materials is of concern to people every where, the work done by the United Nations is of critical importance world-wide. Labels and placards used in the Canadian. IMO. and ICAO regulations are generally based on the U.N. Recomendations. although Canada has some labels and placard designs that vary from the U.N. White borders are optional on International Placards Examples of Wordless Placards and Labels Pictured here are typical wordless placards and labels required for use in Canada and many other countries around the world. Examples of International and Canadian Placards and Labels Spontaneously Combustible and Keep Away From Food placards and labels are used internationally and in Canada. The Corrosive Gas placard and label are used exclusively in Canada. Most placards and labels used internationally are similar (color and symbols) to those required by DOT regulations UN Class Numbers Class 1: Explosives Class 2: Gases (compressed, liquified or dissolved under pressure Class 3: Flammable liquids Class 4: Flammable solids or substances Class 5: Oxidizing substances. Division 5.1. Oxidizing substances or agents Division 5.2, Organic peroxides Class 6: Poisonous and infectious substances Class 7: Radioactive substances Class 8: Corrosives Class 9: Misc. dangerous substances Examples of Explosive Labels Flammaole For complete details, refer to one or more of tne following Code of Federal Regulations. Title 49. Transportation. Pans 100199. [All modes] International Civil Aviation Organization (ICAO) Technical Instruc tions for the Safe Transpon of Dangerous Goods by Air [Air] International Maritime Organization (IMO) Dangerous Goods Code [Water] "Transportation of Dangerous Goods Regulations" of Transport Canada. [All Modes] The Numerical Designation represents the Class or Division Alphabetical Designation represents the Compatibility Group (for Ex plosives only). Division Numbers and Com patibility Group combinations can result in over 30 different "Explosives" labels (see IMDG Code/ICAO). U.S. Department of Transportation Research and Special Programs Administration Available from: American Labelmark Co 5724 N. Pulaski Rd. Chicago. IL 60846 Toll Free: 1-800-621-5808 In Illinois: 312-478-0900 STYLE H-DOT 9 CHART 9 PFV NOVEMBER 1988 ABDOO130770 METRIC CONVERSION CHART When the value in the Column 2 of each conversion type is being used as the SI (Metric) Unit the U.S Value will be in Column 3. When the value in the Column 2 is being used as the U.S. Value the SI (Metric) equivilent will be in Column 1. WEIGHT 12 3 kg <4b kg:> lbs 0.113 0.227 0.34 0.454 0.907 2.268 4.536 6.804 9.072 11.34 13.61 18.14 22.68 27.22 205 1028 0.25 0.5 0.75 1 2 5 10 15 20 25 30 40 50 60 454 2268 0.551 1.102 1.653 2.205 4.409 11.02 22.05 33.07 44.09 55.12 66.14 88.18 110.2 132.3 1001 5000 VOLUME- Gals 123 L <Gal L> Gals 0.946 1.893 2.839 3.785 7.571 18.93 37.85 56.78 75.71 94.64 113.6 151.4 189.3 208.2 450.1 1703 0.25 0.5 0.75 1 2 5 10 15 20 25 30 40 50 55 118.9 450 0.066 0.132 0.198 0.264 0.528 1.321 2.641 3.962 5.282 6.603 7.923 10.56 13.21 14.53 31.4 1188 VOLUME- LITERS 1 23 L < Qt L:> Qt 0.237 0.473 0.71 0.946 1.893 3.786 9.464 14.2 18.93 0.25 0.5 0.75 1 2 4 10 15 20 0.264 0.529 0.793 1.057 2.114 4.228 10.57 15.86 21.14 TEMPERATURE 12 3 C <F O F -73.3 -100 -148 -45.6 -50 -58 -31.7 -25 -13 -17.8 0 32 -6.67 20 68 -5 23 73.4 -3.89 25 77 0 32 89.6 9.99S 50 122 22.72 72.9 163.2 22.78 73 163.4 36.11 97 206.6 48.88 120 248 59.99 140 284 60.55 141 285.8 79.44 175 347 93.32 200 392 PRESSURE 1 kPa 6.894 101.3 103.4 468.8 689.4 698.4 1724 1930 2068 5033 2 cPsi Kpa >psi 1 14.7 15 68 100 101.3 250 36.25 280 40.6 300 43.5 730 105.9 3 0.145 2.132 2.175 9.86 14.5 14.69 Appendix V (0691) C1991 GSI Computer Services Inc., Branson, MO 65616 Reprinted with permission, All rights reserved.