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

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