Simplify — Use “permanent” shipping papers for partial deliveries
Shipping paper requirements can be tricky for companies delivering partial loads of hazmat (liquified petroleum gas, for example) to several locations throughout the day. The driver starts with a volume of hazmat that declines as deliveries are made. The hazardous material stays the same, but the volume changes. Must a driver create a new shipping paper or revise an existing shipping paper to reflect partial delivery of a product?
The answer? No. The solution? “Permanent” shipping papers.
Quantity must be indicated, except …
For transport by highway, the regulations (in 172.202(a)(5)) require that the total quantity of hazardous materials covered by the description on the shipping papers must:
- Be indicated by mass or volume (or by activity for Class 7 materials); and
- State the unit of measurement, for example, “440 pounds” or “13 gallons.”
Here’s the exception: Bulk packages don’t need the indication of mass or volume, as long as some indication of the total quantity is shown. For example, “1 cargo tank” or “2 IBCs.”
But how should that quantity be tracked as deliveries are made and the quantity changes throughout the day?
Permanent shipping papers cover deliveries
Instead of using a separate shipping paper for each delivery, a carrier may use a single shipping paper, without change, for multiple shipments of one or more hazardous materials. This option, found in 172.201(e), only applies when each separate hazardous material has the same shipping name and identification number.
The document, known as a “permanent” shipping paper, allows a carrier to:
- Use a shipping paper without change for multiple shipments of one or more hazardous materials having the same shipping name and identification number, and
- Retain a single copy of the shipping paper, instead of a copy for each shipment made.
To use this option, the carrier must retain a record of each delivery made that includes:
- Shipping name,
- Identification number,
- Quantity delivered, and
- Date of shipment.
However, if a driver picks up additional quantities of hazardous materials that were not previously indicated on the shipping paper, the additional quantities must be added if the total quantity on the vehicle exceeds that indicated on the shipping papers. This requirement is explained in Interpretation Response #03-0247 from PHMSA.
Key to remember: Carriers may use “permanent” shipping papers, instead of a separate shipping paper for each delivery, but must retain copies of delivery or billing receipts as a record of each delivery.