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Tips on DOT Incident Reporting for Undeclared Hazmat

Posted on 12/11/2023 by Roger Marks

Hazardous materials offered into transportation in packages, container, or vehicles without legally required labels, markings, and/or documentation pose substantial danger to employees, drivers, supply chain workers, law enforcement, customers, and the public. 

The US Hazardous Materials Regulations (HMR) refer to these shipments as "undeclared hazardous materials."

Anyone who encounters an "undeclared" hazmat package will have no idea that the package contains hazardous materials—until it's too late. If hazmat leaks from an undeclared package, those nearby will be caught off-guard, with no information about what the material is, its hazards, how to respond to a spill or fire, or even if immediate evacuation is the right thing to do. 

The problems undeclared hazmat shipments cause don’t end there. To comply with the HMR, the unlucky person who discovers an undeclared shipment must fill out and submit a hazardous materials incident report (Form F5800.1). 

Tips on DOT Incident Reporting for Undeclared Hazmat

Discovery of an undeclared hazardous material is one of several circumstances that require the person in possession of the package to submit a written report to US DOT/PHMSA.

How to Report Undeclared Hazardous Materials 

Filling out hazmat Incident Report Form 5800.1 is especially tough when you are the person who discover an undeclared hazardous material. Because undeclared hazmat has no proper labels, markings, or documentation to tell you what's inside (or what spilled out) of the package, container, or vehicle, you likely won't have much of the information the form asks for. 

In a Frequently Asked Questions published for stakeholders, DOT PHMSA offers some guidance about how to fill out a hazmat incident report form if and when an undeclared hazardous material is discovered: 

What information is required on the incident report form for an undeclared shipment?

PHMSA's answer:

The nature of an undeclared shipment is such that complete information about the shipment may not be known at the time of discovery.

If the undeclared shipment is discovered because material was released from the package during transportation, then the information in Part II and Part III of the incident report should be completed to the extent that specific information is known. Similarly, Parts IV and V of the report concerning the consequences of the incident should also be completed.

If the undeclared shipment is discovered and no material was released from the package, then the person filing the report should provide as much information as possible, including the carrier information in item 10 of Part II, the shipper/offeror information in item 11 of Part II, and the shipment origin and destination information in items 12 and 13 of Part II.

For all reports related to undeclared shipments, the events that led to the discovery of the undeclared shipment should be included in Part VI of the report.

Finally, for all reports related to undeclared shipments, Part VIII should be completed to provide contact information. For information that is not known at the time the undeclared shipment is discovered, an indication on the report that the information is not known is acceptable.

PHMSA FAQs on Hazmat Incident Reporting

Using Hazmat Interpretations and FAQs

The answers PHMSA provides in the FAQ do not create any legal requirements. They are meant to clarify, explain, and help stakeholders to interpret the regulations. By create a hazmat incident reporting FAQ and making this information easier to find, DOT hopes to eliminate repeated requests for specific Letters of Interpretation.

More: FAQs on hazmat and hazardous waste training requirements for shippers and RCRA generators. 

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