How Much Hazmat Is One Truck Load?
Hazmat travels in an astonishing variety of packaging types and sizes—from pipettes and vials to cans, boxes, cylinders, drums—all the way to tanker trucks that hold 10,000 gallons or more.
As part of their responsibility under the law, shippers of hazardous materials are required to communicate how much hazmat is in each shipment and the type of packaging used.
Quantity and packaging type are among the mandatory elements of the hazardous material description required on shipping papers. This info is crucial to supply chain safety and security for several reasons, not least of all that emergency responders may rely on shipping papers during a transportation incident or hazmat release.
How the shipper indicates hazmat quantity, packaging type, and number of packages is important, too. To comply with the Hazardous Materials Regulations (HMR), not any descriptor will suffice.
Hazmat Shipping Papers: Quantity, Number and Type of Packages
In general, except when shipping by aircraft (which requires more detail), shipping papers for hazmat in non-bulk packages must indicate:
- the total net quantity of hazardous material by mass or volume, including the applicable unit of measurement—e.g., “200 kg” or “26 gallons”—and
- the number and type of packages, by description of the package—e.g., “12 drums.”
[49 CFR 172.202(a)(5) and (a)(7)]
For bulk packages, on the other hand, shippers must include “some indication of the total quantity” on shipping papers. Examples: “1 cargo tank” or “2 IBCs.”
Getting It Right: Recent PHMSA Interpretation
While the requirement for bulk packages is slightly more flexible, shippers nonetheless must indicate total quantity in a way that sufficiently describes the cargo. Not too long ago, a member of law enforcement contacted PHMSA with a question about showing total quantity on shipping papers.
Specifically, the officer asks if the description “1 TRUCK LOAD” is sufficient to meet the requirement for “some indication of total quantity” to be included for a bulk shipment.
PHMSA says no.
“Although ‘1 TRUCK LOAD’ indicates a general description of the total quantity for the shipment, it is the opinion of this Office that it does not adequately describe the type for packaging containing the hazardous materials being transported and could result in frustration of the shipment.”
Letter to Mr. Nick Wright of the Kansas Highway Patrol. PHMSA Ref No. 22-0117. July 24, 2024.
PHMSA contrasts “1 TRUCK LOAD” with an acceptable description, “cargo tank motor vehicle” or “CTMV." The acronym CTMV appropriately describes a type of package (a cargo tank), PHMSA says, whereas “1 TRUCK LOAD” does not.
When filling out shipping papers for hazardous materials, shippers should take care to meet all requirements in 49 CFR 172.202. That includes showing quantity and package type in a way that adequately describes the shipment.
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