A shipping paper is a document prepared in accordance with the Hazardous Materials Regulations (Part 172, Subpart C). This term covers any shipping order, bill of lading, waybill, manifest, or other document serving a similar purpose.
With a few exceptions, a shipping paper is required to accompany each shipment of hazardous materials during transportation. This requirement may be met by a photocopy of the shipping paper or by a carrier-prepared shipping paper such as a freight bill or waybill. Electronic versions of the shipping paper are NOT permitted during transportation; the shipping paper must be in hard copy/printed format. For shipments of hazardous waste, the original shipper-prepared hazardous waste manifest is the only authorized documentation. A hazardous waste manifest is a shipping paper prepared on the Environmental Protection Agency (EPA)’s uniform hazardous waste manifest, Form 8700-22. All hazardous wastes subject to Title 40, Part 262 must be identified on this form. The original hazardous waste manifest must accompany each shipment from the point of pickup to its final destination and appropriate copies of the document must be properly distributed. Copies are provided for the generator, transporter and treatment, storage or disposal (TSD) facility.
When are hazmat shipping papers required?
- Hazardous Materials Regulations require specific information to be included on the shipping papers that accompany most shipments of hazardous materials.
It is the responsibility of the shipper to properly prepare the shipping paper tendered with the shipment of hazardous materials to the initial carrier. The carrier, in turn, must be certain that the shipping paper is properly prepared prior to accepting the shipment.
The Hazardous Materials Regulations require that specific information be included with the shipping papers. The regulations leave it up to the shipper to determine the format of the shipping papers.
Exceptions (172.200)
Shipping papers are not required for a material, unless it is a hazardous substance, hazardous waste, or marine pollutant, that:
- Has “A” in Col. (1) of the hazmat table, except when offered/transported by air;
- Has “W” in Col. (1) of the hazmat table, except when offered/transported by water;
- Is a limited quantity, except when offered/transported by air or water;
- Is a Category B infectious substance prepared in accordance with 173.199.
In addition, shipping papers are not required for materials transported as Materials of Trade.
Basic hazmat description
- Hazardous materials that are being transported must be described on the accompanying shipping paper using the relevant information found in the Hazardous Materials Table.
Each hazardous material that is offered for transport must be clearly described on the shipping paper using the applicable information from the Hazardous Materials Table.
This shipping description must include the material’s:
- Identification number;
- Proper shipping name;
- Hazard class or division number
- Subsidiary Hazard Class(es) or Division number(s) entered in parentheses, if required;
- Packing group, if any;
- Total quantity (mass or volume or activity for Class 7 or net explosive mass for Class 1) and unit of measurement; and
- Number and type of packages. (172.202)
Example: 2 drums, UN1717, Acetyl chloride, 3, (8), II, 180 lb.
Subsidiary hazard Classes or Divisions must be included, in parentheses, when subsidiary labels are required. Unless excepted, a subsidiary label is required when indicated in Column 6 (Label Codes) of the Hazardous Materials Table, or by 172.402.
Example: UN1463, Chromium trioxide, anhydrous, 5.1, (6.1, 8), II
The total quantity is not required for hazardous material packages containing only residue (i.e., one that has not been cleaned and purged or refilled with a non-hazardous material), for cylinders, and for bulk packages. However, some indication of total quantity must be shown for cylinders and bulk packages (such as 10 cylinders or 1 cargo tank).
Examples:
- 8 cylinders, UN1072, Oxygen, compressed, 2.2
- 1 IBC, UN1789, Hydrochloric acid, 8, II
- 1 cargo tank, UN1267, Petroleum crude oil, 3, II
The first five items — often referred to as the material’s basic description — must be shown in sequence, with no additional information interspersed unless authorized by the regulations. The identification number must include the letters “UN” or “NA” or “ID”, as appropriate. The packing group must be shown in Roman numerals and may be preceded by the letters “PG”. (172.202)
Examples:
- UN1203, Gasoline, 3, PG II
- UN2359, Diallylamine, 3, (6.1, 8), II
- NA1911, Diborane mixtures, 2.1
Additional description categories
- Additional information about a hazardous material, such as its technical name, reportable quantity, and more, must sometimes be included on a shipping paper along with the basic description.
Sometimes, additional information is required with the basic description. See 172.203 for more information.
Technical names
With some exceptions, proper shipping names identified by the letter “G” in Column (1) of the Hazardous Materials Table (HMT) must include technical names in parentheses. Most not-otherwise-specified (n.o.s.) and other generic proper shipping names must have the technical name of the hazardous material entered in parentheses in association with the basic description. The word “contains” may be used with the technical name. The regulations allow that if a technical name is required, it may be entered between the proper shipping name and the hazard class or following the basic description.
Organic peroxides which may qualify for more than one generic listing, depending on concentration, must include with the technical name the actual concentration being shipped or the concentration range for the appropriate generic listing.
A Division 6.2 material with the ID number UN2814 or UN2900 that is suspected to contain an unknown Category A infectious substance must have the words “suspected Category A infectious substance” entered in parentheses in place of the technical name.
If a hazardous material is a mixture or solution, the technical names of at least two components most predominately contributing to the hazards of the mixture or solution must be entered. A mixture or solution not identified specifically by name in the HMT — that consists of a non–hazardous material and a hazardous material identified in the HMT by technical name — may be described using the proper shipping name of the hazardous material and the qualifying word “mixture” or “solution”, as appropriate. In 172.101(c)(10) some restrictions apply, such as the hazard class, packing group, or subsidiary hazard of the mixture or solution must be the same as the hazardous material identified in the table.
Example: The proper shipping name for a solution of Brucine and a non-regulated material could be “Brucine solution.”
Except for some Class 7 descriptions, if the name of a hazardous substance is not identified in the proper shipping name for a material, the name of the hazardous substance must be entered in parentheses in association with the basic description. If a material contains two or more hazardous substances, only the names of the two substances with the lowest reportable quantities (RQs) must be entered. For hazardous waste, the waste code (such as D001), if appropriate, may be used to identity the hazardous substance.
Examples:
- UN1760, Corrosive liquids, n.o.s. (Caprylyl chloride), 8, II
- UN3102, Organic peroxide type B, solid, 5.2, (dibenzoyl peroxide, 50-100%)
- UN2924, Flammable liquid, corrosive, n.o.s., 3, (8), II (contains methanol, potassium hydroxide)
- NA3082, Hazardous waste, liquid, n.o.s. (D001), 9, III, RQ
Reportable quantity (RQ)
If the material is a hazardous substance, the letters “RQ” must appear either before or after the basic description. The letters “RQ” may be entered in an HM Column on a shipping paper in place of the “X.”
Limited quantity
When a shipping paper is required for a material being shipped as a limited quantity, the words “Limited Quantity” or the abbreviation “Ltd. Qty” must be entered following the basic description.
Elevated temperature material
The fact that a material is an elevated temperature material must be indicated in the proper shipping name (such as “Molten” or “Elevated temperature”) or the word “HOT” must immediately precede the proper shipping name.
Poisons
For all materials meeting the poisonous by inhalation criteria, the words “Poison-Inhalation Hazard” or “Toxic-Inhalation Hazard” and the words “Zone A,” “Zone B,” “Zone C,” or “Zone D” for gases, or “Zone A” or “Zone B” for liquids, as appropriate, must be added on the shipping paper immediately following the shipping description. For anhydrous ammonia transported within the U.S., only the words “Inhalation Hazard” must be added in association with the shipping description.
Marine pollutant
If a material is a marine pollutant, the words “Marine Pollutant” must be entered in association with the basic shipping description, unless the proper shipping name indicates that it is a marine pollutant.
Empty packaging with residue
For other than tank cars, the description on the shipping paper for a packaging containing only the residue of a hazardous material may include the words “RESIDUE: Last Contained * * * ” immediately before or after the basic description of the hazardous material last contained in the packaging.
For a tank car containing residue, the description on the shipping paper must include the phrase “RESIDUE: LAST CONTAINED * * * ” immediately before or after the basic shipping description or immediately preceding the proper shipping name of the material on the shipping paper.
Organic peroxides and self-reactive materials
For Division 5.2 (organic peroxide) and Division 4.1 (self-reactive) material, the following information must be included in the description on a shipping paper, as appropriate:
- When temperature control is required for transport, the control and emergency temperature;
- The word “SAMPLE” in association with the basic description for samples; or
- If notification or competent authority approval is required, a statement of approval of the classification and conditions of transport.
Non-odorized LPG
When non-odorized liquefied petroleum gas is offered for transportation, the word “non-odorized” or “not-odorized” must be included in association with the proper shipping description on a shipping paper.
Shipping paper specifications
- Hazardous Materials Regulations require certain specific information, such as number of pages and special permit numbers, to be included with shipping papers.
The Hazardous Materials Regulations require that specific information is included with the shipping papers.
Format
The regulations leave it up to the shipper to determine the format of the shipping papers.
Page numbers
A shipping paper may consist of more than one page, if each page is consecutively numbered and the first page bears a notation specifying the total number of pages included in the shipping paper. For example, “Page 1 of 4 pages.”
Special permits
For a shipment of hazardous materials made under a special permit, the shipping paper must bear the notation “DOT-SP” followed by the number issued for the special permit. The notation must be clearly associated with the description to which the special permit applies.
Additional information
A shipping paper may contain additional information not inconsistent with the required hazardous materials information. This information must follow all the information required by the hazardous materials regulations.
Prohibited entries
No shipping paper entry shall identify a material as hazardous by hazard class or identification number unless the material described is a regulated hazardous material.
Identifying hazmat vs. non-hazmat on a shipping paper
- When listing hazmat and non-hazmat on the same shipping papers, the hazmat must be highlighted by order of listing, color, or a check box to indicate which of the materials are hazardous.
Hazardous materials are required to be indicated on shipping papers in one of three ways when non-hazardous materials are also listed.
1. | The hazardous materials must be listed first, before any non-hazardous materials
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2. | The hazardous materials must be entered in a color that clearly contrasts with non-hazardous materials entries (hazardous materials entries may be highlighted only on reproductions of the shipping paper)
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3. | The hazardous materials must be identified with an “X” in a column captioned “HM” placed before the basic shipping description
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Emergency response information
- Hazmat shipments must include emergency response information, including the name of the material, health hazards, explosion risks, precautions to take immediately, and more.
Most hazardous material shipments (except those that do not require shipping papers) must have emergency response information on or in association with the shipping paper. If the information is in association with the shipping paper it may be in the form of the Emergency Response Guidebook, a Safety Data Sheet, or any other form that provides all the information required by the regulations.
The following emergency response information is required:
- Basic description and technical name of the hazardous material;
- Immediate hazards to health;
- Fire and explosion risks;
- Precautions to be taken immediately;
- Immediate methods for handling fires;
- Initial methods for handling spills or leaks in the absence of fire; and
- Preliminary first aid measures.
This information must be on or kept with the shipping papers, away from the packages containing the hazardous material and in a location immediately accessible in the event of an incident.
Emergency response telephone number
- An emergency response telephone number, which is monitored by a person who has knowledge of the hazmat, must be included with the shipping paper.
In most cases, an emergency response telephone number must be entered on the shipping paper. It can be immediately following the description of each hazardous material, or if the number applies to every hazardous material entered on the shipping paper, entered once on the shipping paper in a clearly visible location and identified as an emergency response information number.
The emergency response phone number must be monitored at all times that the hazardous material is in transportation, by a person who has knowledge of the hazardous material and has comprehensive emergency response and incident mitigation information for the material or has immediate access to such a person.
The emergency response telephone number must be:
- The number of the person offering the hazardous material for transport, when that person is also the emergency response information provider; or
- The number of an agency or organization (emergency response information telephone service provider) capable of and accepting responsibility for providing the response information. The person registered with the emergency response information telephone service must ensure that the service has the current information on the material before it is offered for transport.
When the person offering hazardous materials for transport is also the emergency response telephone information provider, that person’s name must be entered on the shipping paper near the emergency response telephone number. In addition, when the telephone number of an emergency response information (ERI) telephone service provider is used, the name of the person who is registered with the ERI service provider, or the contract number or other unique identifier assigned by the ERI provider, must be placed on the shipping paper near the emergency response telephone number. However, the above requirements do not apply if the name or identifier is entered elsewhere on the shipping paper in a prominent, readily identifiable, and clearly visible manner where it can be easily and quickly found.
The emergency response telephone number requirements do not apply to:
- Limited quantities;
- Materials described with the shipping names listed in 172.604(d)(2); or
- Vehicles or containers containing lading that has been fumigated and display the FUMIGANT marking, unless other hazardous material is present.
Shipper’s certification
- A shipper’s certification indicates that the hazmat being is being shipped in compliance with Hazardous Materials Regulations.
When a shipment is offered to the initial carrier, the shipping paper must bear the prescribed shipper’s certification. This certification indicates that the hazardous material is being offered in compliance with the Hazardous Materials Regulations.
No certification is required for the return of an empty tank car which previously contained a hazardous material and which has not been cleaned or purged.
Except for hazardous waste, a shipper’s certification is not required for the highway transport of hazardous materials when:
- Transported in a cargo tank supplied by the carrier, or
- Transported by the shipper as a private carrier, unless the material is to be re-shipped or transferred from one carrier to another.
The following two shipper’s certifications are authorized for use:
“This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.”
“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations.”
For shipments by air the following certification is authorized:
“I hereby certify that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packaged, marked and labeled, and are in proper condition for carriage by air according to applicable national governmental regulations.”
On any shipment moving by air, the following statement must be added to the required certification:
“I declare that all of the applicable air transport requirements have been met.”
Shipper’s certifications must be printed (manually or mechanically) on the shipping paper. The certification must be legibly signed by an authorized representative of the shipper. The signature may be applied manually, by typewriter, or other mechanical means. On hazardous waste manifests the signature must be handwritten.
Hazmat shipping paper retention
- Most hazmat shipping papers must be retained by carriers and/or shippers for a period of one to three years, depending on the circumstances.
Hazmat shipping papers must be retained by the carrier for one year after the material is accepted and by the shipper for two years after the material is accepted by the initial carrier.
The hazmat shipping paper that is retained may be a paper copy or an electronic image. The shipping paper copy or image must be accessible at or through the principal place of business and must be available, upon request, to an authorized official at reasonable times and locations. The date of acceptance by the carrier must be included on the retained shipping paper.
A motor carrier that uses a shipping paper without change for multiple shipments of a single hazardous material (same shipping name and identification number) may retain a single copy for each shipment made, IF the carrier also retains a record of each shipment made. This record must include the materials shipping name, identification number, quantity transported, and date of shipment.
Hazardous waste manifests (172.205) (shipping papers) must be retained for three years after the material is accepted by the initial carrier.