HAZMAT Certification

Basic Rules for Shipping Papers

Fot HAZMAT certification, a shipping paper for hazardous materials transportation is any document that contains the information required to describe the hazardous material being transported. It may include a shipping order, a bill of lading, a hazardous materials manifest, or any other type shipping document serving a similar purpose and containing the required information. Only in the case of hazardous wastes is there a prescribed shipping paper format – the hazardous waste manifest.

The basic rule for shipping papers is that if you transport any quantity of any hazardous material, a properly prepared shipping paper must accompany the shipment. This includes materials identified as hazardous substances, hazardous wastes, and marine pollutants. The basic rules for describing and identifying hazardous materials in transportation are quite simple: Mark the package, label the package, prepare a shipping paper with all the information, including emergency response information, and placard the vehicle. Now let's look at the exceptions to the basic rules regarding shipping papers that cause the most confusion among people handling hazardous materials. Please see the 40 hour HAZWOPER training course for more info.

There are certain shipments of hazardous materials that do not require description as hazardous materials on a shipping paper.

HAZMAT Certification Shipping Paper Exceptions

Some of the more common exceptions include:

• Hazardous materials with an 'A' in column 1 of the HMT offered or intended for transportation only by highway, rail, or vessel, unless the material is identified as a hazardous substance, a hazardous waste, or a marine pollutant and then it is regulated in all modes of
transportation;

• Hazardous materials with 'W' in column 1 of the HMT offered or intended for transportation only by highway, rail, or air, unless the material is identified as a hazardous substance, a hazardous waste, or a marine pollutant and then it is regulated in all modes of transportation;

• Small quantity shipments prepared in accordance with §173.4;
• Certain agricultural shipments prepared and transported in accordance with §173.5.
• Materials of Trade shipments prepared in accordance with §173.6;
• Certain U.S. Department of Energy and U.S. Department of Defense shipments prepared in accordance with §173.7; and
• Shipments of ORM-D, unless transported by air, in accordance with §172.200(b) (3).

Example

Say you are shipping Dibromodifluoromethane by vessel, with no intention that it will make any leg of its journey by air. Assume that this Dibromodifluoromethane is not waste.

- Since it does not appear in Table 1 or Table 2 of Appendix A, it is not a hazardous substance.

- Since it does not appear in the List of Marine Pollutants, it is not a marine pollutant.

- Finally, since it is identified by the letter "A" in Column 1 of the HMT, and since it is not being offered or intended for transportation by air, it meets the first shipping paper exception: "Shipments with a letter "A" in column 1 of the HMT, if shipped by highway, rail, or vessel only".

- So this shipment of Dibromodifluoromethane, under the circumstances presented, would not require description as a hazardous material for hazmat certification on a shipping paper. For additional HAZWOPER information please see the list below.