Unknown Hazmat: Secrets for Shipping Samples
Information or no, the material still needs to be shipped, and the shipment is subject to regulation. So, how do you properly ship a potential hazardous material when you don’t have the information you would typically use to classify, package, mark, label, and handle it? Read on to find out!
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If you don’t have enough information to classify an unknown hazardous material, sending it to a lab for analysis if often a great choice. The 49 CFR hazmat regulations provide some slight relief from regulation for shipping samples, defined as small amounts of potentially hazardous materials of which the hazard class is uncertain and needs to be determined by testing, to be shipped to the testing lab with slight reductions in regulation. [49 CFR 172.101 (c)(11)]
The shipper must determine a preliminary hazard class and packing group based upon the information that is known or user knowledge. For example, if you have a liquid that you believe is a flammable liquid, but you do not know the flash and boiling points, you may assign Hazard Class 3 and use the Proper Shipping Name of Flammable Liquid n.o.s.
Your Best Guess on Classification and Naming
49 CFR 172.101 has three entries for flammable liquid n.o.s., one for each of the three packing groups. The shipper can choose the packing group he believes best applies to his material based on the limited information he may have. Since you may not know the chemical makeup of the material, the technical names of the material that are normally required in parenthesis after the Proper Shipping Name are excluded. [49 CFR 172.101(c)(11)]
For ground shipments, the word sample must be added either in front of or after the Proper Shipping Name.
The same goes for air and vessel shipments—the word sample must be added after the name.
Shipping Hazmat Samples by Air or Vessel
If the name that is chosen for the material is forbidden from transport by the word “Forbidden” in Column 3 of the 49 CFR 172.101 Table or is a material described in 49 CFR 173.21, 173.54, 173.56(d) and (e), 173.224(c), or 173.225(b) (e.g., materials that can cause a dangerous evolution of heat and certain self-reactive materials), you may not ship it as a sample.
How to Package Hazmat Samples for Transport
When packaging the material, the applicable standards of general packaging requirements and special provisions must be met in addition to the applicable packaging authorizations. [49 CFR 173]
Shippers may choose to follow the authorized packaging requirements from Column 8A or Column 8B of the 172.101 Table.
For example, the shipper could choose to ship the material by the limited or excepted quantity rules referenced in Column 8A and use good, strong boxes or the fully regulated rules in Column 8B and use a 4G fiberboard box with authorized inner receptacles.
Either way, combination packaging must be used. Combination packagings include inner receptacles inside and an outer packaging, (e.g., plastic bottles in a fiberboard box). The amount of hazardous material is limited to a net mass of 2.5 kg (5.5 lbs.). The sizes of the inner receptacles are limited by the method of shipment chosen.
How to Complete Shipping Papers for Hazmat SamplesWhether shipping papers are required depends on the method of shipment chosen. Generally, shipping papers are not required for limited quantity and excepted quantity shipments, but are required for fully regulated shipments (i.e., those prepared according to Column 8B).
When you do prepare shipping papers for sample shipments, all required elements of the basic description must be included—UN number, proper shipping name, hazard class, packing group, and the type and quantity of packaging used.
In addition, the word SAMPLE should precede the proper shipping name, as we discussed above.
UN1993, SAMPLE Flammable liquid n.o.s., 3, II 1 Fiberboard box X 3 lbs.
Another option to ship samples to the lab for analysis is to take advantage of the materials of trade exception at 49 CFR 173.6.
Using the Hazmat “Materials of Trade” Option
The materials of trade exception allows shippers to transport small amounts of hazardous materials and receive breaks from the more stringent fully regulated or even the limited quantity regulations. If certain quantity limits are complied with, materials may be transported in a personal or company vehicle without the need for specification packaging, some hazard markings and labeling, shipping papers, and even placards.
Sending a material to a lab for analysis is a great way—and sometimes the only reasonable way—to acquire the information you need to properly classify a material according to 49 CFR 173. Even though the regulations lay out slightly relaxed requirements for samples, the shipper must still ensure the material is shipped safely and in full compliance.
New hazmat employees need a solid grasp of the hazmat regulations and what they must do to help maintain compliance. Every step of the hazmat shipping process is regulated in some way, and even small mistakes can lead to fines now approaching $80,000 per day, per violation.
Hazmat Training for New and Experienced Hazmat Employees
The Shipping Hazmat by Ground—Ops Online Course provides hazmat general awareness, security awareness, and function-specific training for new or experienced hazmat employees. Personnel who complete this course learn the keys to hazmat compliance, and how to comply with the regulations that govern each type of hazmat job.
Have questions about training your team? Reach out to us at info@Lion.com and we will be happy to provide some clarity on who needs training, what training they need, and how to get it all accomplished.
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