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When to Modify a Hazmat Shipping Name

Posted on 8/12/2021 by Roseanne Bottone and Roger Marks

Imagine three cousins, all named Jack. Sometimes, more than one Jack shows up to a family function.

When this happens, the rest of the family uses "modifiers" to tell the Jacks apart. Family members call the oldest one Old Jack, the tallest one Big Jack, and the third one "Weird Jack." Don't ask!

By adding one word to each cousin's name, family members communicate important detail and limit confusion. 

A similar dynamic is at play when shippers name hazardous materials for transportation.

In certain circumstances, shippers must modify the proper shipping name (PSN) of a material before it can be offered for transportation The modified name must appear on shipping papers, package markings, and anywhere else the PSN is found.

4 Required Hazmat PSN Modifications

1. “Waste”
Hazardous wastes that meet one or more of US DOT’s criteria for hazard classes 1—8 are named using standard DOT naming protocol. Shippers must select the most accurate, specific name available from the Hazmat Table.

Shippers then add the word “Waste” before the proper shipping name. For example: Waste acetone.

Adding the word “Waste” communicates that the material meets the US DOT’s definition of a hazardous waste in 49 CFR 171.8 and that the shipment must be accompanied by a Uniform Hazardous Waste Manifest.

DOT Class 9 Hazardous Wastes. Hazardous wastes that do not meet the criteria for any DOT hazard class 1 through 8 are regulated as Class 9, “miscellaneous” hazardous materials in transportation. These wastes may be named Hazardous waste liquid, n.o.s. or Hazardous waste solid, n.o.s. 

Because the words "hazardous waste" already appear in these Class 9 shipping names, shippers do not need to add the word “Waste.”

2. “Mixture” or “Solution”

A hazmat mixture or solution that is not identified by name (e.g., “Acrylamide solution” or “Chlorate and borate mixtures"), comprised of a single predominant hazardous material and—
  • Traces of one or more hazardous materials, and/or
  • Non-hazardous material
—must be described using the proper shipping name of the predominant hazardous material and the qualifying word “mixture” or “solution.”

Example: When you mix acetone (a hazardous material) with water, you call it "acetone solution" if the hazards still match those of acetone (i.e. Hazard Class 3, Packing Group II). 
Adding the word mixture or solution communicates that the material is not the “pure” chemical. However, it must have the same hazard class and packing group as the predominant hazardous material.

Exceptions to this rule are found at 49 CFR 172.101(c)(10)(i)(A)-(F).

3. “Sample”
If a sample of a material is shipped for testing to determine its hazards, it is legal to assign a “tentative” hazard class, proper shipping name, and packing group based on the shipper’s knowledge of the material.

Anyone handling a shipment with a PSN that includes the word “sample” should assume it’s possible the information is not entirely accurate and be particularly cautious; After all, the sample is being sent to a lab to test for its constituents and properties.

Except when the word “Sample” already appears in the proper shipping name (e.g., “Gas sample, non-pressurized, flammable, n.o.s., not refrigerated liquid) the word “Sample” must be added as part of the proper shipping name or in association with the basic description on the shipping paper. For example: “Sample flammable liquid, n.o.s.”

4. Adding Technical Names
Some proper shipping names provide very little identifying information about the hazardous material they describe—flammable liquids, n.o.s. (UN 1993), for example.

When a shipper selects one of these "generic" shipping names, identified by a “G” in Column 1 of the 172.101 Table, the PSN must be supplemented with technical names of the constituents that predominantly contribute to the material's hazard or hazards ("acetone and acetonitrile," for example). The samples discussed above are excluded from this requirement.

Further reading: Generic vs N.O.S. Hazmat Names

A technical name must also be added when shipping marine pollutants and reportable quantities of certain substances with ambiguous proper shipping names, like “wood preservatives, liquid.”

Shippers must choose the most accurate, descriptive proper shipping name available for a hazardous material before it may be shipped by any mode of transportation. The modifications required for some proper shipping names, in some situations, provide extra detail that can enhance the safety of anyone handling the material throughout the cycle of transportation.

10 Steps to Compliant Hazmat Shipments

Want more detail about how to classify, name, package, and document hazardous materials shipments? Lion's Hazmat Ground Shipper Certification training guides new shippers through Lion’s 10-Step© process for preparing safe, compliant hazardous materials shipments. 

Train online at your own pace or join us when our popular in-person workshops return to Nashville, Atlanta, Houston, Dallas, San Diego, Cincinnati, and Chicago in 2021. Want the best of both worlds? Attend a live, instructor-led webinar

Hazmat Training Required by Law

If you ship hazardous materials like flammable liquids, corrosive chemicals, lithium batteries, infectious substances, and many others, US DOT requires you to complete training to safely prepare shipments.

Training is required within 90 days of hire date for new “hazmat employees”—including employees who perform pre-transportation functions like classification and naming, selecting packaging, labels, shipping papers, and more. Recurrent hazmat training is required once every three years (49 CFR 172.704).

Hazmat Training FAQ.

Tags: 49 CFR 172, DOT compliance, hazardous materials, hazmat shipping

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