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DOT Rules for Modifying Hazmat Shipping Names

Posted on 5/23/2017 by Roger Marks, Flip De Rea, Joel Gregier

“A rose by any other name would smell as sweet,” Shakespeare wrote in Romeo and Juliet. The same might be said for hazardous materials—no matter what Proper Shipping Name you choose, your material will exhibit the same hazards and be just as dangerous to supply-chain workers and emergency response personnel. That’s why choosing the right shipping name is so important.

Once you’ve chosen the most accurate, most specific Proper Shipping Name (PSN) to describe your material from the table at 49 CFR 172.101, you may find you need to modify that name to be more precise about what you’re shipping. While modifying the PSN won’t change the hazards of your material, modifications often provide critical information for personnel to use in the event of a release or other incident.

US DOT’s Hazardous Materials Regulations (HMR) require you to make certain modifications to the Proper Shipping Name. The following list is not intended to be exhaustive, but to give you a primer on some of US DOT's required hazmat shipping name modifications. 


5 Required DOT Hazmat Shipping Name Modifications

1. When shipping hazardous wastes, you must add the word “Waste” in front of the Proper Shipping Name, for example, “Waste acetone.” US DOT defines a hazardous waste as any material that requires the use of the Hazardous Waste Manifest (per 40 CFR Part 262) for transport. 

Exception: If your PSN already includes the word waste, such as the name “hazardous waste, liquid, n.o.s.,” you are not required to add the word “waste.”
 
2. When shipping a sample of a material for analysis—if the hazard class is uncertain and must be determined by testing—you must add the word “Sample” either before or after the PSN.Note: If you ship by air or vessel, the IATA DGR and the IMDG Code require the word “Sample” to be placed AFTER the Proper Shipping Name.

CFR-and-hazmat-package.gif3. Hazmat mixtures and solutions: When shipping a single hazardous material found on the 172.101 table that’s been combined with a non-hazardous material (e.g. water), you must add the word “mixture” or “solution” to the PSN.  This rule applies only when the resulting mixture or solution still exhibits the hazards of your original material. If the mixture of solution exhibits different hazards, you would select a different PSN from the 172.101 table. 

Like many hazmat requirements, there are some exceptions to this naming convention for mixtures and solutions. If you have questions about naming a hazmat mixture or solution, contact us at info@Lion.com so we can provide more complete guidance.  
 
For information on US DOT’s criteria for identifying mixtures and/or solutions, see 49 CFR 172.101(c)(10). For tips on classifying your hazmat mixtures—check out this post: Classifying Hazmat Mixtures on the Dark Side.  
 
4. A number of Proper Shipping Names in the 172.101 table are “generic” shipping names. These are indicated with a “G” in Column 1 of the table. Whenever you have a generic PSN, you must supplement it with a technical name of the material. 
For example, the shipping name for UN 1993, “flammable liquids, n.o.s.” is a generic shipping name. Therefore, you must add a technical name—acetone, for instance—in parentheses after the name.
 
5. Adding a technical name is also required when you ship a marine pollutant or a reportable quantity (RQ) of a substance—if, and only if, you cannot tell from the PSN what the marine pollutant is or what is triggering the reportable quantity.

Example: "Wood preservatives, liquid" - Not all liquid wood preservatives are marine pollutants, and there is no reportable quantity for “wood preservatives.” So, when you use the Proper Shipping Name “Wood preservatives, liquid” in concert with the marine pollutant label or the letters “RQ,” you must add the technical name of the specific chemical that makes your wood preservatives toxic to aquatic life and/or for which the RQ is present.

That covers five of the required modifications to hazmat Proper Shipping Names. Other modifications to PSNs are allowed, but not required. Stay tuned—we will cover the optional Proper Shipping Name modifications in next week’s Lion News.

Old Bill Shakespeare might be right—a rose smells sweet no matter what you call it. But when it comes to hazmat, the name you give your material—and how you modify that name—is absolutely crucial to safe transportation. 


June Hazmat Shipper Training (DOT, IATA, and IMDG) 


To help shippers protect employees and maintain full compliance with the latest hazmat transportation regulations, Lion Technology presents the Complete Multimodal Hazmat Shipper Certification Workshops in cities nationwide.

US DOT requires all hazmat employees to complete training within 90 days of hire and repeat hazmat training once every 3 years thereafter.


June 2017 DOT, IATA, and IMDG Hazmat Training Dates

Cleveland June 6—9
Houston June 6—9
Dallas June 12—15
Pittsburgh June 12—15
Detroit June 19—22
Cincinnati June 20—23

See the schedule for complete DOT (ground), IATA (air), and IMDG (ocean) hazmat shipper training here.


 

Tags: DOT, hazmat, hazmat shipping

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