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How to Ship Hazmat with No Packing Group

Posted on 10/16/2023 by Roger Marks

Not all hazardous materials are equally hazardous. Even within the same hazard class or division, the severity of the hazard posed by different materials can vary greatly. For example: Some flammable liquids (Class 3) ignite at lower temperatures than others, making them more susceptible to an incident during transportation or storage. 

Packing Groups (PGs) address this by sorting hazardous materials within the same hazard class or division based on the “degree of danger” they present—great danger (PG I), moderate danger (PG II), or minor danger (PG III). The packing group for a hazardous material is shown in Column 5 of the Hazmat Table in 49 CFR 172.101. 

Shippers use hazardous material packing groups in two important ways: 

  • To communicate the degree of danger the material poses on shipping papers; and
  • To determine the strength of packaging required to contain the material in transportation. 
But not all types of hazardous materials are assigned to packing groups. Gases (Class 2), infectious substances (Division 6.2), and radioactive material (Class 7) are not assigned packing groups. Neither are "articles" like lithium batteries or aerosols.   

Selecting Hazmat Packaging with No Packing Group (PG)

When hazmat is assigned to packing groups, the PG (I, II, or III) corresponds to a UN package rating of X, Y, or Z. Only X-rated packagings are authorized for PG I materials (great danger) or lower. Y-rated packagings may be used to ship PG II materials or lower, and Z-rated packagings may be used for PG III materials (minor danger) only. 

Without a packing group to go on, shippers must use other available info to determine the strength rating of packaging required for their hazmat. Luckily, the packing instructions for the material in Section 173 of the HMR and/or the Special Provisions associated with the material will specify the type and strength of packaging required. 

Hazmat Shipping Papers with No PG 

When filling out hazmat shipping papers, the Packing Group is a required element of the basic description (when applicable). When a material has no packing group, you simply don't include it. Materials with no packing group are excepted from requirement to include PG on shipping papers [see 49 CFR 172.202(a)(4)].

When a material does not have a PG, it is important that it is not included. Extraneous, inaccurate information included on shipping papers or package markings can create confusion in the supply chain, cause delays, and put shippers at risk of liability for violating the HMR.

For those used to shipping flammable liquids or corrosive chemicals, encountering a material with no PG may be confusing or disorienting at first. By paying close attention to details elsewhere in the HMR, though, shippers can still find the details needed to select the right package and offer any hazmat for transportation in full compliance with the HMR—with or without a packing group.

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