6 Picky Parts of Hazmat Shipper Papers
An improperly completed or incomplete shipping paper will delay or prevent the transportation of your materials. Because the shipping paper is so important to safe hazmat transportation, the requirements for this document are detailed and specific. Let's pick apart the six most picky parts of hazmat shipping papers.
First, it’s important to note that the ground and vessel regulations do not require the use of a specific form. Any document, such as an invoice or Bill of Lading (BOL), can be your shipping paper if it contains all the necessary information. That said, your carrier may still require the use of a specific form.
When shipping hazardous materials (i.e. dangerous goods or DG) by air, offerors are required to complete a specific form called the Shippers Declaration. If you ship a hazardous waste and the EPA requires the use of a uniform hazardous waste manifest for the shipment, a printed copy will fulfill your shipping paper obligation for the materials included on it.
So, what information is needed to make a hazardous materials shipping paper complete? Essentially, these six things: A “Basic Description” of each material, a total quantity for each material, the number & type of packages used, a signed certification of accuracy, the date transportation began, and a phone number to call in the case of emergencies.
1. The Basic DescriptionEach hazardous material is required to have a “Basic Description”, which consists of the following components in the following order: The Identification Number; the Proper Shipping Name (PSN); the Hazard(s); and the Packing Group (PG) (if it has one). NOTE: Item 9b of the uniform hazardous waste manifest does not describe this information in this order, but does require this information in this order.
Common errors in the Basic Description include: missing components, putting the required components in the wrong order, not putting UN, NA or ID (as appropriate) in front of the identification number, using an invalid PSN, using abbreviations and/or chemical symbols in the PSN, improper placement of technical names (when needed), and not using roman numerals for the PG,
2. UnitsShipping papers are required to show how much hazmat is being shipped and how it’s packaged. Ground and vessel shipping require a “total-total” which is hard to mess up as the regulations allow for mass or volume, gross or net. It’s likely though, that your carrier will have a preference. Air transport requires a much more nuanced “unit total” (per package or overpack) and care should be taken.
While abbreviations may be used to express units of measurement and types of packaging, they must be “commonly accepted and recognizable”. Other common errors include using non-metric units on air or vessel shipments and using the UN spec code in place of the packaging type. NOTE: The Hazardous Waste Manifest requires the use of form-specific abbreviations for units of measure and packaging.
3. Certification and hazmat trainingShipping papers require a signature certifying that every part of the pre-transportation process has been completed according to the applicable regulations. In order to sign shipping papers for the transport of hazardous material to, from or within the US, the signer must have comprehensive training on the requirements of US DOT PHMSA's Hazardous Materials Regulations (HMR).
In almost all cases signing shipping papers for dangerous goods transport by air or vessel requires training in those regulations in addition to the required DOT training (see IATA DGR 1.5 and IMDG Code 1.3.1).
The big mistake here is allowing someone to sign a shipping paper who has not been properly trained. And while the DOT allows for the use of mechanical and electronic signatures, some national authorities and some carriers/transporters do not. It’s best to check beforehand.
Earlier this year, PHMSA provided guidance for signing hazmat shipping papers during the COVID-19 public health crisis.
4. DateEach shipping paper must include the date of acceptance by the initial carrier. For rail, vessel, or air shipments, the date on the waybill or bill of lading may be used as the date of acceptance.
5. Emergency Response InformationThe first page of all shipping papers must have an Emergency Response Telephone Number visible which will connect the caller with someone knowledgeable at any time during transportation.
Common errors include using numbers that don’t connect to someone knowledgeable about the material’s hazards and their mitigation (Security, call-back services, voicemail, etc.); using a third-party for this service, but not including the account number with the phone number, especially when the original shipper isn’t clearly indicated elsewhere on the page; and using a toll free (800, 888) number that cannot be called from areas your material will be traveling through and to.
6. Modal differencesThe air (IATA DGR) and vessel (IMDG Code) regulations specifically require that the shipper’s and receiver’s name and address be indicated on the first page of a shipping paper.
If your shipping paper is more than one page, be sure to mark the first page as “1 of N”, where N is the total number of pages. If the shipping paper contains both hazmat and non-hazmat, the hazmat must be distinctly identified.
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