5 Basic Steps for HazMat Shipping Success
If you have had any interaction with the 49 Code of Federal Regulations (CFR) as a HazMat shipper, you know that the regulations are complex, can strike fear in the hearts of most just by reading them, and that they can be the source of frustration if not followed correctly.
The most recent increases in DOT civil and criminal fines (August 2016) should serve as an incentive for shippers to create regulation-based procedures that will support a HazMat shipping process in efforts to ensure compliance. These procedures should not only reinforce the shipper’s training, but also serve as a reminder of the basics that must be followed every day and for every shipment.
Consider Making These Your Top 5:
1) Classification: HazMat chemicals or articles are common items that we come in contact with every day. Determining the classification can sometimes be difficult and confusing. The best way to obtain classification is to always consult the Safety Data Sheet (SDS) or the Product Data Sheet (PDS). After consulting the SDS or the PDS, one should be able to determine whether a chemical or an article is a hazardous material (HazMat). If the chemical or article is not a HazMat, then the rules in 49 CFR do not apply; however, if the chemical or article is a HazMat and is going to be offered for transportation, then the rules in the 49 CFR apply.
2) Use the Correct Name: After determining that the chemical or article is a HazMat, a name must be chosen to reflect either its chemical classification, component, or hazard characteristics. The Proper Shipping Name (PSN) must be chosen from the Hazardous Materials Table (HMT) and could be a basic name or a generic name. A basic proper shipping name, such as Acetone, indicates exactly what the item is. In contrast, a generic proper shipping name such as Flammable Liquids, N.O.S., indicates that the item is composed of one or more components. Determining the proper shipping name is a key action that ensures compliance with the 49 CFR. Without a PSN, packages can’t be properly packaged, marked or labeled; and emergency responders will be unable to provide immediate assistance should there be an incident involving the hazardous material.
3) Packaging: One of the key responsibilities of a HazMat employee is to ensure that the HazMat shipment does not pose an unreasonable risk to health, safety or property. As a result, the HazMat must be placed and remain in the shipping container during the entire transportation process. In order to effectively accomplish this task, the HazMat employee must know the difference between types of packaging such as: nonbulk vs. bulk, combination vs. single and nonspecification vs. specification. Some of the most common violations noticed by DOT are the uses of unauthorized shipping containers and package failures.
4) Use of Marks and Labels: Although they look similar and are applied to the shipping container in the same manner, marks and labels are different and each has an important purpose. Marks convey additional information and can be used with a wide variety of hazard classes or divisions. Marks inform the acceptor of any additional requirements the HazMat may have. On the other hand, labels are uniquely tied to the nine hazard classes or divisions. Each label has a specific color and design that indicates the hazard’s characteristics.
5) Documentation: Whether the HazMat is being shipped by ground, air, or ocean, the shipping document tells the complete story about the Hazmat being offered. It is a legal document that must be legible, in English, and signed. It is important for a HazMat employee to remember that the DOT does not endorse a standard or universal shipment document; however, the DOT does require that the information presented on the shipping document be arranged in a specific sequence: Identification Number, Proper Shipping Name, Hazard Class or Division, and Packing Group. If any of the required information is omitted, the shipment will be returned or held until corrected.
After completing these five steps, a HazMat employee would do well to follow one last step—always review the shipment before offering it. Remember, the HazMat employee is the first person to see the shipment but they will NOT be the last.
LaQuita Donald, CHMM,CDGP, is the Environmental and Hazardous Materials Compliance Manager at Motion Industries.