Hazmat Shipping Regulations: Domestic vs International

Posted on 3/20/2012 by James Griffin

Q. Why can’t I just follow the DOT rules for all modes of transport? Why are there separate rules for air and vessel?
A. The U.S. Department of Transportation (DOT), under the authority granted by Congress in the Hazardous Material Transportation Act (HMTA), promulgates and enforces the Hazardous Material Regulations (HMR) that govern the safe and secure transportation of hazardous materials in the United States. The HMR are codified in Title 49 of the Code of Federal Regulations (49 CFR), Chapter I, Subchapter C, Parts 171-180. A material is subject to the Hazardous Material Regulations (HMR) when it is:
  1. Designated as hazardous by the Secretary of Transportation;
  2. Transported to, from, or through the United States;
  3. In commerce; and
  4. Transported by a regulated mode of transportation (railroad, aircraft, vessel, or motor vehicle on a public road). [49 CFR 171.1]
All four criteria must be met for the HMR to apply.
While the HMR do include some rules that apply only to certain modes of transportation, most of the regulations apply equally to all modes. Domestic and International Hazmat ShipmentsThe DOT does have rules for each mode of transport. However, from a practical standpoint, there is a good chance you will not follow DOT’s air and vessel rules.Hazmat Ground Shipping
International Regulations
When dangerous goods (or even non-hazardous materials) are moved across international boundaries, they must comply with the regulations of multiple countries. The shipment must follow the regulations of the countries of origin and destination, and sometimes the rules from each country of transit or the carrier’s home country.
Because a multiplicity of different rule sets would burden international commerce, the governments of the world have agreed on harmonized international standards. These international standards are codified in the International Civil Aviation Organization (ICAO) Technical Instructions for transport by air and the International Maritime Dangerous Goods (IMDG) Code, for transport by vessel.
The U.S. DOT authorizes shipments of hazardous material to follow these international standards, in lieu of 49 CFR, for transport by aircraft or vessel respectively. [49 CFR 171, Subpart C] Public safety regulators in most other countries have similar authorizations.
Air shipments can be confusing. In most cases, you will end up following the International Air Transport Association (IATA) Dangerous Goods Regulations, rather than 49 CFR or the ICAO Technical Instructions. This is perfectly legal, as the IATA regulations are nothing more than the ICAO instructions with additional safety precautions added by the air carriers themselves, reformatted to be easier to read. Therefore, any shipment or package that complies with all applicable IATA rules is already in full compliance with the ICAO rules.
Domestic Shipments
At this point, you may think that the ICAO and IMDG hazmat rules apply only to international shipments. This is not the case. The DOT authorizes shippers and carriers to use international regulations for domestic shipments when all or part of the transport will be by aircraft or vessel. Air and vessel carriers tend to be globalized businesses, which have an interest in setting worldwide standards. Consequently, many operators will insist that shippers follow international standards for domestic shipments whenever the DOT allows and will refuse all DOT-air or DOT-vessel shipments. This is a business practice, not an enforceable regulation.
As a final note, if you do end up using the IATA DGR or IMDG Code for your air or vessel shipments, there are still some extra DOT requirements that must be met. These can be found at 49 CFR 171.23-171.25. They include, but are not limited to, requirements for emergency response info, U.S. training standards, and registration requirements.
How Do I Learn the Domestic and International Hazmat Rules?
Lion Technology offers a comprehensive four day Multimodal Hazmat Shipper Certification Workshops covering the rules for all three modes.  For the convenience of our students, we also offer online hazmat training.

Tags: DOT, hazmat shipping, IATA, IMDG

Find a Post

Compliance Archives

Lion - Quotes

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

Download Our Latest Whitepaper

Use this guide to spot which tanks and substances are regulated under EPA's Underground Storage Tank program, and which are excluded as of October 2018.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.