In the world of hazardous material (dangerous goods) shipping, there are some very important documents that need to be squared away before the shipment departs your facility. For the context of this post, we will be talking exclusively about shipping papers for United States domestic shipments. We will cover international shipments and compare the two in other posts.
The United States Department of Transportation has created an informational hotline you can call with hazardous materials questions! Give them a call at 1-800-467-4922 and they can help answer questions you may have about hazardous shipments.
What Are Shipping Papers?
Shipping papers, in the context of US domestic, are relatively simple and easy to understand single page documents. In most events, your bill of lading will have all the required information to meet the requirements for dangerous goods shipping papers.
Shipping papers are used for a few things in the process of shipping, we'll explore ocean transportation:
- This document provides vital information to the shipping company to keep their employees safe. Ocean carriers use the shipping paper information to compile a list of what's hazardous, where it is, and how much is on board. This is usually referred to as a Dangerous Cargo Manifest (or DCM). These lists are essential to crews of ships and carriers to determine the best spot to place the cargo on board and more importantly, how to respond to an emergency like a fire more effectively and safely.
- This document provides the marine terminals the same benefit it provides that ship. Terminals have requirements to keep cargo segregated to minimize the dangers of an accidental release or fire. Shipping papers also give the terminal vital information to pass along to first responders - fire fighters and first aid - in the event of a fire or injury.
- These documents are required by federal law - but so are taxes. Why are they important and why does the federal government care so much? United States Department of Transportations and Homeland Security are concerned with dangerous goods and their proper documentation for the same reasons above but, also to ensure truckers know what they're carrying and that everyone in the process of shipping knows of the hazards involved.
When shippers don't declare their hazardous cargo on a bill of lading or other hazardous declaration (which some do to avoid extra fees or to carry a load over the road without a hazardous cargo license) they create problems for everyone. Imagine a container full of a class 5.1, ammonium nitrate (fertilizer high-nitrate) liquid leaking from its container and covering the containers below it.
Do I Need Shipping Papers?
If you are shipping any hazardous materials then you are required to send shipping papers to the carrier, at the latest, when the shipment is picked up for transportation. 49 CFR 172.200
What is included on Shipping Papers?
Shipping papers have a few requirements for their contents that come from 49 CFR 172.200-205. Some of them include (but are not limited to):
- Identification number of the material. This officially comes from the Hazardous Materials Table (HMT) that comes from 49 CFR 172.101.
- Proper shipping name & technical name, and subsidiary hazard(s) of the material.
- The hazard class & packing group.
- Number and type of packages, total quantity of the material.
- If shipping a class one explosive, the net explosive mass.
- Limited quantity or reportable quantity, or residue last contained.
- Emergency contact information.
- Shippers certification statement: "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."
How to fill out a shipping papers
Starting with 172.201 (CFR references are mind-numbingly boring to read but provide immensely valuable information) and working through the section:
- Contents - This is simply a list of what the shipment contains written in English without codes or abbreviations. If you are shipping non-hazardous materials with dangerous good, then list the dangerous goods/hazardous materials first. Check the column "HM" with an X (or RQ if appropriate). Write all information required in 172.202 (we'll cover soon).
- If the shipping papers are multi-page, then place "page x of x" on the papers.
- Shipping papers must contain an emergency contact phone number (if using a emergency service provider, identify the person by name or contract number who has a contractual agreement with the service)
Describe the hazardous materials in the following way:
- Provide the identification number from the HMT table
- Write the proper shipping name from HMT table column 2.
- Write the hazard class * or * division number for the material from column 3 or following the basic description for US Domestic shipments. .
- No hazard class is not needed for entry "Combustible liquid, n.o. s."
- Write the packing group in roman numerals from column 5 ( Class 1 materials; self-reactive substances; batteries other than those containing lithium, lithium ions, or sodium; Division 5.2 materials and materials without a packing group are exempt).
- Add total quantity of hazardous material covered by their description in a unit of measurement like 200 kg (440 pounds) (class 7 describe activity of material). See 172.202(5)(i)-(iii) for complete list of exemptions.
- Technical and chemical group names may be entered in parentheses between the proper shipping name and the hazard class or after the basic description.
- Shipping dangerous goods in small quantities may mean the shipment falls into a limited quantity exemption. When a shipping paper is required for a limited quantity shipment, the words "Limited Quantity" or "Ltd Qty" must appear following the basic description.
- There are some class specific requirements from 172.203
You are required to keep a record of the shipping papers for two years (three years is hazardous waste) in a controlled access area or digitally and must be made readily available upon request to the DoT or FMCSA inspector.