DOT Hazardous Materials – Understanding the Core Requirements
The transportation of hazardous materials (HazMat) within the United States is governed by the Hazardous Materials Transportation Act, with its purpose being to “protect against the risks to life, property, and the environment that are inherent in the transportation of hazardous material.” The regulations, which were created under the passage of this act, can be found in Title 49 of the US Code of Federal Regulations (CFR). These standards set forth the requirements for material classification and labeling, provide for packaging specifications, and afford operational rules that must be followed to ensure the safe transportation of hazardous materials.
A hazardous material is defined by the Department of Transportation (DOT) as “a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has been so designated.” This includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature materials. Common examples of DOT hazardous material include:
- Compressed gases
- Reactive materials
- Organic peroxides
- Poisonous materials
- Radioactive substances
There are many requirements that must be followed to ensure that hazardous materials are transported safely. The hazardous material must first be identified and described using a Proper Shipping Name (PSN) found in the HazMat Table (49 CFR 172.101). Proper Shipping Names are determined based on the physical state, properties, and intended uses of the material. This may be a specific-use name such as copper-based pesticide, liquid, or toxic, a chemical name such as Xylene, or it may be a more general hazard class description such as corrosive liquid, acidic, organic, or n.o.s. (not otherwise specified). Note that general hazard class descriptions will typically require additional information to be included alongside the Proper Shipping Name, like the technical names of the hazardous ingredients. Hazardous wastes will also require the word “waste” preceding the Proper Shipping Name. Once a Proper Shipping Name has been determined, the information contained for the row entry of the HazMat Table will be the guide for providing the information needed to send the HazMat on its way in a safe and compliant manner. This information includes the hazard class or division, the HazMat identification number, the packing group, label codes, special provisions, exceptions, acceptable packaging, quantity limitations, and vessel stowage information.
Following the designation of the Proper Shipping Name, the next step is to select the packaging that will be used to transport the HazMat. The hazardous materials packaging must be compatible, appropriate, and authorized for such use. Most shipments of HazMat necessitate the use of packaging that conforms to United Nations (UN) Performance Oriented Packaging (POP) requirements, indicated by a marking applied to the exterior of the package by the package manufacturer. Packaging for HazMat is subdivided into three groups:
- Bulk packaging for large volume shipments in containers greater than 119 gallons
- Non-bulk packaging for smaller shipments less than 119 gallons
- Exception packaging for categorically defined small volume Limited Quantity shipments
Depending on the type of hazardous material to be shipped, these containers may be drums, pails, jerricans, boxes, bags, composite packaging, or a pressure receptacle.
Once a package has been selected, the required markings and labels will need to be applied to the exterior of the package. Markings typically found on a HazMat package include the United Nations identification number, the Proper Shipping Name, and the information communicating a responsible party. Specific hazards may also require the application of additional markings to communicate that a material is either a marine pollutant, is being shipped in a Limited Quantity, possesses an inhalation hazard, or is designated as an overpack. A label is the 3.9” square-on-point, which communicates the primary and subsidiary hazard associated with a HazMat. These labels contain the numeric hazard class or division at the bottom, are color-coded, and include a hazard class-specific symbol. When multiple labels are required, they must be applied immediately adjacent to one another to ensure effective communication.
Following the marking and labeling of the package, the shipment will need to be documented on a shipping paper. Shipping papers come in many forms but are most commonly encountered as a bill of lading or a hazardous waste manifest. Key elements of a shipping paper – which are required regardless of the type of shipping paper – include the basic description (ID#, Proper Shipping Name, Hazard Class, and Packing Group), emergency response information, and a signed shipper certification. Other required elements that must be communicated on shipping papers include the total quantity of the material being shipped, the packaging type, and the number of packages offered for shipment.
When loading the HazMat onto the transport vehicle, it is important to consider the compatibility of the HazMat with the other hazardous materials on the vehicle. There are many incompatibilities that will prohibit transport or require the segregation of different types of hazardous materials being shipped together. To determine materials compatibility, you will need to reference the Load Segregation Table to determine how the HazMat must be stored, loaded, and transported; this is found in 49 CFR 177.848.
Before allowing the HazMat shipment vehicle to depart, the final step is to verify the application of placards, when required. Placards are larger versions of labels that are placed on the exterior of the transport vehicle. These placards will contain either the identification number or text indicating the hazards of the HazMat loaded onto the vehicle. The shipper of a HazMat is required to have placards available for the types of placardable quantity hazardous material shipments they may send out and to provide them upon request when shipping a placardable quantity of HazMat. The tables that delineate when placarding is required are found in 49 CFR 177.504.
Finally, the performance of any of these tasks classifies an employee as a DOT HazMat employee, which requires triennial training on DOT HazMat regulations. The DOT defines a HazMat employee as any person who is employed on a full-time, part-time, or temporary basis who, in the course of such employment, directly affects hazardous materials transportation safety. Specifically included are those employees who
- Load, unload, or handle hazardous materials
- Design, manufacture, fabricate, inspect, mark, maintain, or recondition HazMat packaging
- Prepare hazardous materials for transportation
- Are responsible for the safety of transporting hazardous materials
- Operate a vehicle used to transport hazardous materials
U.S. Compliance can help if you discover opportunity areas when it comes to your DOT HazMat training obligations. Whether it be through onsite training or via our frequently held webinar trainings, we offer a variety of solutions to train your staff on DOT HazMat regulations to help keep you up to date and in compliance.