Available Now: 2023 Schedule of Hazmat & RCRA Training

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

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

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

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

These are the best classes I attend each year. I always take something away and implement improvements at my sites.

Kim Racine

EH&S Manager

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

Download Our Latest Whitepaper

Spot and correct 4 of the most common universal waste errors before they result in a notice of violation during a Federal or state inspection.

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.