Search

Question of the Week: Shipping Samples Under 49 CFR 172.101(c)

Posted on 9/22/2011 by James Griffin

Q. I have a material I need to ship off site that might be a DOT hazmat, but I’m not sure. I want to send a sample to a laboratory for testing, but how do I do that if I don’t know what its properties are? What do I have to do to ship this sample in compliance with the DOT’s regulations when I don’t know what kind of hazmat it is in the first place?
 
A. Fortunately for you, the DOT has considered this conundrum. 
 
When you have a material and you are unsure what kind of hazmat it is, you may tentatively assign a Proper Shipping Name, hazard class, identification number, and packing group in order to ship a sample to a place where it can be analyzed. Your tentative classification will be based on your knowledge of the material, the hazard class criteria and definitions in 49 CFR Part 173, and the precedence of hazards prescribed in 49 CFR 173.2a (49 CFR 172.101(c)(11)).
 
Once you have picked a tentative shipping name and description for your sample, you will package, mark, label, prepare shipping papers, offer placards, and in all other ways follow the hazardous material regulations as if it were any other hazmat shipment; provided you comply with the following additional requirements and restrictions:
 
  • The sample must be packed in a combination packaging. 
  • The net mass of the sample cannot exceed 2.5 kg (5.5 lbs.). 
  • You must add the word “SAMPLE” to the Proper Shipping Name on the package markings and shipping papers, unless it is already present. 
For shipping names that include a “G” in Column 1 of the 172.101 Hazardous Material Table, you typically must add the technical name of the hazardous constituent(s) to the description on the shipping papers and package markings. If you don’t know what the primary hazardous constituents are, then you don’t need to include a technical name when you ship a sample for analysis under Section 172.101(c)(11).
 
These reliefs for unclassified samples do not apply to: 
 
  • Forbidden materials described at 49 CFR 173.21; 
  • Explosives described at 49 CFR 173.54, 173.56(d), and 173.56(e); 
  • New self-reactive materials (49 CFR 173.224(c)); and 
  • New organic peroxides (49 CFR 173.225(b)). 
 

Tags: DOT, hazmat shipping, marks and labels, shipping papers

Find a Post

Compliance Archives

Lion - Quotes

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional Manager

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

Download Our Latest Whitepaper

The definitive 10-step guide for new hazardous materials shipping managers. Quickly reference the major considerations and details that impact hazmat shipping compliance.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.