Basic Description Order Phase Out
When shipping fully regulated hazmat packages, all shippers must create shipping papers to provide hazard information to their carriers and emergency responders. The core element of a hazmat shipping paper is the “basic description” of each hazardous material in the consignment. [49 CFR 172.202(a)] The basic description is made up of the following four elements, in order:
- Identification Number
- Proper Shipping Name
- Hazard Class or Division
- Packing Group (if applicable)
You may notice that these elements are in the same order as the column headings in the List of Dangerous Goods (IATA DGR 4.2) and the Dangerous Goods List (IMDG Code 3.2).
Ages ago, the U.S. Department of Transportation authorized shipping papers to display the basic description in this order:
- Proper Shipping Name
- Hazard Class
- Identification Number
- Packing Group
This order is the same as the column headings in the Hazardous Materials Table (49 CFR 172.101), and form the mnemonic anagram “SHIP.”
In 2007, the DOT amended the Hazardous Material Regulations to harmonize the order of elements in the basic description with international standards. In part because expensive legacy database systems were already in place under the old method, the DOT implemented the rule change with a lengthy 6-year phase-in period.
That phase-in period ends in 76 days.
As of January 2, 2013, the U.S. DOT will consider it a violation of the HMR to offer shipping papers that list the Proper Shipping Name first.
Keep in mind that dicta on the U.S. EPA’s Uniform Hazardous Waste Manifest still refer to the old order, and we have no reason to believe it will be revised any time soon. As the DOT is the agency that enforces transportation, go with its instructions until the EPA catches up.
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Tags: DOT, hazmat shipping, shipping papers
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