Hazardous Materials
scoobizzle
Ch.6pg179-199.pdf
All forms of packaging intended for containerization of a haz- ardous material is subjected to rigorous testing procedures pre- scribed by DOT to ensure that they will retain their integrity when subjected to normal conditions of transportation. There are five principal tests for each type_ of packaging: drop test; leakproofness test; hydros_ta_nc test; sta_ckmg test; and vibration test. DOT pub- lishes the mm1mum reqmrements for compliance with these tests at 49 C.F.R. Subpart M.
A shipper may petition DOT to containerize a hazardous mate- rial for t~ansport~tion in an unconventional fashion by submitting relevant mformat1on to demonstrate that the packaging retains its integrity when subjected to normal conditions of transportation. When DOT agrees, it assigns the shipper an approved special per- mit as "DOT-SP-" followed by the assigned special permit number. The assignment of an approved special permit allows carriers to legally transport a hazardous material in unauthorized packaging for a specified period, after which the shipper must reapply for a new special permit.
6.1-F SPECIAL PROVISIONS
FIGURE 6.2 This intermediate bulk container may be used to transport sulfuric acid. (Courtesy of Avantor Performance Materials, Inc., Center Valley, Pennsylvan ia, "Packaging Systems: Innovative Design Drives Productivity". )
DOT identifies certain special provisions that apply to the trans- portation of unique hazardous materials. Each provision is identi- fied by a code. We are primarily concerned here only with the provisions that apply directly to the needs of emergency-response personnel.
When shippers and carriers transport a gaseous or liquid hazardous material that poses a health hazard by inhalation, DOT requires them to establish its hazard zone. For gases, the hazard zone is any of the designations Zone A, Zone B, Zone C, or Zone D; and for liquids, it is either Zone A or Zone B. The greatest degree of health hazard is posed by exposure to hazardous materials that have been assigned to Zone A.
The code for the hazard zone of a hazardous material that poses health hazard by inhalation appears in column 7 of the Hazardous Materials Table. When DOT lists any of the codes 1, 2, 3, or 4 in column 7, shippers and carriers associate them with Zone A, Zone B, Zone C, and Zone D, respectively.
6.2 THE SHIPPING PAPER With few exceptions, DOT requires a hazardous material to be properly described for transportation on a shipping paper. There are several forms of a shipping paper, such as a shipping order, bill of lading, manifest, railroad waybill, or similar document. Most resemble the example shown in Figure 6.3, a portion of which we shall use as a template throughout the remainder of this text. For emergency responders, the information entered in the section noted as "Shipping Description" is especially important.
6.2-A SHIPPING DESCRIPTIONS OF HAZARDOUS MATERIALS DOT requires shippers to provide the shipping description of each hazardous material in a given consignment on the accompanying shipping paper. The shipping description of a hazardous material is composed in part of a composite listing of the following compo- nents in the sequence noted.
health hazard by inhalation The expression used to describe the property of certain gases and liq- uid vapors that could cause health problems when inhaled
hazard zone For pur- poses of DOT regula- tions, any of the four hazard levels assigned at 49 C.F.R. §§173.11 G(a) and 173.133(a), respec- tively, to poison gases and either of the two levels (Zones A and B) assigned to liquids whose vapors pose a health hazard by inhalation
shipping paper The shipping order, bill of lading, air bill, dangerous-cargo mani- fest, or similar shipping document issued by a
• "UN/NA" Identification number shipper or carrier as 1
required by DOT at 49 Proper shipping name (including the technical name in parentheses, when applicable) C.F.R. §§172.202,
1 Primary hazard class or division 172.203, and 172.204 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 179
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ll No,
-OF Non-Negotiable BILL OF LADING I Trailer No:
-----------lTruck No: I Dispatch/Pro No: Driver: I Date Received: CHAR~ CONSIGNEE SHIPPER
Name Name Street Address Street Address City, State
City, State Phone
Notify/Contact Phone Notify/Contact ----
PARTICULARS FURNISHED BY SHIPPER - Shipping Descriptio~ Primary Hazard
(Identification Number, P~ofer Shipp:~la:;:; Division, and Weight Class or Division, Subsidiary Hazar (lb)
Units HM Packing Group)
I Placards Required: I Emergency Telephone: I ERG No. For hazardous materials transported by vessel : Shipper de- This is to certify that the above-named materials are proper~ clares that the packing/loading of freight containers and/ classified, described, packaged, marked and labeled, and are in or transport vehicles containing hazardous materials has proper condition for transportation according to the been carried out in accordance with the provisions of applicable regulations of the Department of Transportation 49 c.F.R. §176.27(c). (49 C.F.R. §172.204). Signature: Signature: --
LIABILITY FOR LOSS, DAMAGE, ETC. TO GOODS --- Shipper's attention is directed to Sectio~ 11 on the rever~e side of this Bill of Lading. All goods shall have an agreed release valuation of S?.10 per pou~d unless Shipper decl?res a h1~he~ value and Carrier accepts that valuation in the space beloW- For water carnage, see Section 5 on the reverse side of this B111 of Lading: Shipper's initials: Higher value: $ per pound Carrier's acceptance:
ORIGIN DESTINATION
time in : time in : · ion time out: time out: Received in good order, count and co
nd11
r d-:-a-te-: ----------t-;d-at_e_: __________ _J unless otherwise noted above.
SHIPPER CONSIGNEE Authorized Signature Date Authorized Signature Date Authorized Signature Date
FIGURE G.3 One form of a shipping paper used in commerce.
180 Chapter 6 Use of the DOT Hazardous Materials Regulations b E Y mergency Responders
,......- 5 bsidiary hazard class or division in parentheses if any
II p~cking group (when applicable) ' 11 r requires ship~ers to provide this information in English on a shipping paper. pO p0T also re~uires the t~tal number of packaging units and the total amount of each
dous rnatenal ma consignment to be communicated in the shipping description. The hazalr umber of units is indicated by such expressions as 4 boxes 17 cylinders 5 steel ota n b 1 1 t k k d f ' ' 1 s 3 glass ott es, an true , an so orth. The total amount is typically provided
drum r~ss aggregate mass or volume. Abbreviations are used to express the common units as a g 1 asurernent. 0 m;OT lists si~ sym?ols in colum_n 1 of the Hazardous Materials Table. When a G is . d p0T requrres shippers to provide the technical name parenthetically with the hazard-
hste ' hi . d . . Wh ous material's s ppm~ escnption. en a + symbol is listed, the proper shipping name, hazard class, ~nd_ packing ~roup may _not be altered for any reason. When a D or I is listed, h proper shipping name is appropriately described for domestic and international trans-
l :Cration, respectively. Finall~, when an A_ or W is listed, DOT regulates the transportation ~/ che given haza~dous material ~nly by aircraft and watercraft, respectively.
When a consignment comprises hazardous materials and other materials whose trans- orcacion is not regulated _by DOT, the proper shipping descriptions of the hazardous
~acerials must be entered first on the relevant shipping paper, or a contrasting color or an X in che "HM" col~mn ~an be entered to identify the entries that are hazardous materials. for example, gasoline, mtrogen, and a flammable solid are listed on the following portion of a shipping paper before the materials that are not subject to the DOT hazardous mate- rials regulations. The hazardous materials are specifically identified by an X in the col- umn headed "HM."
SHIPPING DESCRIPTION (IDENTIFICATION NUMBER, PROPER SHIPPING NAME,
PRIMARY HAZARD CLASS OR DIVISION, SUBSIDIARY HAZARD WEIGHT UNITS HM CLASS OR DIVISION, AND PACKING GROUP) (lb)
10 steel drums X UN1203, Gasoline, 3, PG 11 4500 (UN1A1) 40 cylinders X UN1066, Nitrogen, compressed, 2.2 800 (DOT-3AA 1800) 1 steel drum X UN2926, Flammable solids, toxic, organic, n.o.s. (Cloth/Paper 452 (UN1A1) containing 2,4-dinitrophenol), 4.1, (6.1), PG II
4 boxes (UN4D) Advertising materials, paper, n.o.i. 60
1 roll Paper, printing, newsprint 690
12 sets Carbon paper 22
EMERGENCY CONTACT: (000) 000-0000
This example also illustrates that the shipper must provide an emergency-contact tele- phone number on a shipping paper for each hazardous material within the consignment. In this instance, there are multiple hazardous materials listed on the same paper, and the single telephone number applies to all of them. During a transportation mishap, emer- gency responders secure the shipping paper and provide this number to CHEMTREC.
When providing the shipping description of a hazardous material, shippers must be aware of other DOT regulatory requirements that are relevant to identifying the given consignment by a selected mode of transportation. Examples of these regulations are pro- vided in Table 6.2. They illustrate that emergency-response personnel obtain valuable information about the nature of a unique hazardous materials consignment from the information that has been entered on shipping papers.
shipping description For purposes of DOT
regulations, the follow· ing minimum informa· tion for a hazardous material : proper ship· ping name (including the technical name, when required); hazard class or division; identi• fication number; pack· ing group; total quantity by mass, vol· ume, or as otherwise appropriate; and the number and types of packages
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 181
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TABLE 6.2 RELEVAN
&F@fH,01-- T REGULATION
EXAMPLE {SELECT PHRASES)' Transportation of a Hazardous Material by All Modes h' er or carrier transports a hazardous substan .
RQ, UN1052, Hydrogen fluoride, anhydrous, 8, (6.1), PG I When as Ipp . rt ble q n · ce 1n that exceeds its repo a uan I y in a singl
(Poison - Inhalation Hazard, Zone Cl an amoun~ letters RQ are included before or after the e package, t e shipping description.
or UN1052, Hydrogen fluoride, anhydrous, 8, (6.1), PG I, RQ (Poison - Inhalation Hazard, Zone Cl When a hazardous material, by chemical interaction with
RQ, UN1428, Sodium, 4.3, PG I (Dangerous When Wet) . r ble to become spontaneously flammable or giv water, Is Ia . . e ff fl mable gases in dangerous quant1t1es, the words ~Dan:rous When Wet" are included with the shipping
description.
UN1831, Sulfuric acid, fuming, 8, (6.1), When a hazardous material p~s~~sses multiple hazards, its subsidiary hazard class or d1v1s10~ number~ are entered
PG I (Poison - Inhalation Hazard, Zone B) parenthetically immediately following the primary hazard class.
UN1760, Corrosive liquids, n.o.s. {Valerie acid), 8, PG I When a hazardous material is described with an n.o.s. entry or other generic description in the Hazardous Materials Table, the shipping description includes the name of the substance in parentheses.
UN1992, Flammable liquids, toxic, n.o.s. {contains xylene and When a mixture o,r solution of two or more hazardous
methanol), 3, (6.1 ), PG I materials described by an n.o.s. entry in the Hazardous Materials Table is to be transported, the technical names of at least two components most predominantly contributing to the hazards of the mixture or solution are parenthetically entered in the shipping description.
UN1202, Diesel fuel solution, 3, PG Ill When a mixture or solution of a hazardous material not listed by name in the Hazardous Materials Table and a non-
or hazardous material is to be transported, the proper name of
UN1202, Diesel fuel mixture, 3, PG Ill the hazardous material is entered in the shipping description along with the word "solution" or "mixture."
UN1987, Alcohol, n.o.s. (contains 2-octanol), 3, PG Ill When the name of a hazardous material is not specifically listed in the Hazardous Materials Table, the entry that most appropriately describes the chemical class of the material is used, not its hazard class.
UN2672, Ammonia solutions (with 12.8% ammonia in water), When a concentration range is a component of a proper
8, PG Ill shipping name, the actual concentration of the hazardous material, if it is within the indicated range, is used in lieu of the range. _
UN2789, Acetic acid glacial, 8, (3), PG II (with >80% acid Technic~I and chemical group names may include an . by mass) appropriate modifier like "contains" or "containing" which is entered parenthetically between the shipping name and the or hazard class or following the shipping description. UN2789, Acetic acid, glacial {contain ing more than 80% acid by mass), 8, (3), PG II
• 49 CF.R. §§172.202 and 172.203. bNot provided in this table is the unique information that DOT requires in the shippin d • . . . . d'oac· tlve materials. This information is discussed independently in Sections 13_19_A lS.4
9 d e,stpt,ons of ~rganic peroxides, explo11ves, and ra 1
' The component of the shipping description that Is applicable to the regulat i~n Is 'an_d d.10, respectively. prov, e in blue print.
182 Chapter 6 Use of the DOT Hazardous Materials Regulat ions b E Y mergency Responders
TABLE 6.2 Information Required in Shipping Descriptions (continued)
e)(AMPLE (SELECT PHRASES)
RO, UN2029, Hydrazine anhydrous, 8, (3, 6.1 ), UN2029, pG I (Poison)
or RO, UN2029, Hydrazine anhydrous, 8, (3, 6.1 ), PG I (Toxic)
UN2783, Organophosphorus pesticides, solid, toxic (Ciodrin), 6.1, PG II
or UN2783, Organophosphorus pesticides, solid, toxic, 6.1, PG 1 (Ciodrin)
RO, UN2199, Phosphine, 2.3, (2.1) (Poison - Inhalation Hazard, zone Al
or RO, UN2199, Phosphine, 2.3 (2.1) (Toxic - Inhalation Hazard, Zone A)
Flammable solids, n.o.s. (sod ium), 4.3, UN 1325, PG 11
UN3082, Hazardous waste, liquid, n.o.s., 9, (contains trichloroethylene), PG Ill (F001)d
NA3082, Hazardous waste, liquid, n.o.s., (contains toluene and methanol), 9, PG Ill (EPA ignitabili ty)
or NA3082, Hazardous waste, liquid, n.o.s., (contains toluene and methanol), 9, PG Ill (D001)
RQ, UN1621, London purple (contains diarsenic trioxide and aniline), 6.1, PG II (Marine Pollutant)
or UN1621, London purple (contains diarsenic trioxide and ani- line), 6.1, PG II, (Marine Pollutant) RQ UN1193, Residue: Last conta ined ethyl methyl ketone, 3, PG II
RELEVANT REGULATION Regardless of the hazard class to which a hazardous material is assigned, if a liquid or solid material in a package meets . the definition of a Division 6.1, PG I or II, and the fact that it is a poison is not disclosed in its shipping name or class entry, either of the words "Poison" or "Toxic" is entered in the shipping description. Notwithstanding the hazard class to which a hazardous material is assigned, if the technical name of the com- pound or principal constituent that causes a m~terial to meet the definition of a Division 6.1, PG I or 11, 1s not included in the proper shipping name for the material, the technical name is entered in parentheses in the shipping description . For materials that pose an inhalation hazard, either of the expressions "Poison - Inhalation Hazard" or "Toxic - Inhalation Hazard" and the applicable words "Zone A," "Zone B," "Zone C," or "Zone D" for gases or "Zone A" or "Zone B" for liquids, are entered on the shipping paper immediately following the shipping description.
If a hazardous material is also a hazardous substance other than a rad ioactive material, and the name of the hazardous material does not identify the hazardous substance by name, one of the following descriptions is entered in parentheses in the shipping description of the hazardous material: (a) the name of the hazardous substance;
or (bl for waste streams, the hazardous waste number;
or (cl for waste streams that exhibit an EPA characteristic, the letters "EPA" followed by the characteristic or the EPA hazardous waste number_d,e
If a hazardous material is also a hazardous substance other than a radioactive material, and the name of the hazardous material does not identify the hazardous substance by name, the letters "RQ" are entered either before or after the ship- ping description.
The shipping description for the residue of a hazardous material contained in packaging other than a rail tankcar may include the words "Residue: Last contained _____ (name of hazardous material in packaging before it was emptied) ."
dThe EPA hazardous waste numbers for listed hazardous wastes are prefixed with one of the capital letters F, K, P, or U. The nature of the listed hazardous wastes is published at 40 C.F.R. §§261.31, 261.32, 261 .33(e) and 261.33(!}. 'Four EPA characteristics of a hazardous waste are identified at 40 C.F.R. §§261.21-261.24: ignitability (Section 3.2); corrosivity (Section 8.15); reactivity (Section 5.9); and toxicity (Section 10.1-B). Hazardous wastes exhibiting these characteristics have been assigned the EPA hazardous waste numbers 0001, 0002, 0003, and D004 through D043, respectively.
(continued)
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 183
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TABLE 6.2
EXAMPLE (SELECT PHRASES) RELEVANT
RQ, UN1052, Hydrogen fluoride, anhydrous, 8, (6.1), PG I When a shipper has been assigned an approved sp . . . h ecIaI (Poison - Inhalation Hazard, Zone C) (DOT-SP- •• •) permit from DOT to containerize a azardous mat . . h h' . enaI, an unconventional fashion, t e s 1pp1ng descriptio in (*** is replaced with the appropriate special permit number) includes the notation "DOT-SP-" followed by the as~ign
special permit number and so located that the notar ed clearly associated with the description to which the I0n is
REGULATION
exemption applies.
UN2214, RQ, HOT Phthalic anhydride, 8, PG Ill If a liquid hazardous material is to be transported at a "elevated temperature," and the fact that it is an elev nt
· I · t d' I d . th h' a ed. temperature matena Is no 1sc ose 1n es Ipping n the word "HOT" immediately precedes the proper ship;~e, . I Ing name of the hazardous matena .
6 cyl (DOT-3AA1 800), RQ, UN1076, Phosgene, 2.3, (8), (Poison - Inhalation Hazard, Zone A)
The number and type of ~ach nonbu_lk packag_e with its Dor specification number are included with the shipping
or description.
5 steel drums (UN1 A1), UN1193, Ethyl methyl ketone, 3, PG 11 Transportation of a Hazardous Material by Passenger- Carrying Railroad or Aircraft
UN1827, Stannic chloride, anhydrous, 8, PG II (Limited When DOT authorizes the transportation of a hazardous Quantity) material in a limited quantity by passenger-carrying railroad or or aircraft, the shipping description includes the words
"Limited Quantity" or "Ltd Qty. " UN1827, Stannic chloride, anhydrous, 8, PG 11 (Ltd Qty)
Transportation of a Hazardous Material by Cargo Aircraft UN2363, Ethyl mercaptan, 3, PG I (Cargo Aircraft Only) When DOT authorizes the transportation of a hazardous (Limited Quantity) material by cargo aircraft, the words "Cargo Aircraft Only"
are entered in the shipping description. UN2363, Ethyl mercaptan, 3, PG I (Cargo Aircraft Only) When DOT authorizes the transportation of a hazardous (Limited Quantity) material in a limited quantity by cargo aircraft, the shipping or description includes the words "Limited Quantity" or "Ltd Qty" in addition to "Cargo Aircraft Only." UN2363, Ethyl mercaptan, 3, PG I (Cargo Aircraft Only) (Ltd Qty) Nonbulk Transportation of a Marine Pollutant on Water and Bulk Transportat ion of a Marine Pollutant in All Modes UN1381, Phosphorus, white, under water, 4.2, (6.1), PG I When a shipper or carrier transports a nonbulk quantity of a (Marine Pollutant) (Poison) marine pollutant on board watercraft or a bulk quantity of a
marine pollutant by any mode, the words "Marine Pollutant' are included with the shipping description. -
UN1621, London Purple (contains diarsenic t rioxide and When the name of the component causing a material to be a aniline), 6.1 , PG II (Marine Pollutant) (Poison) marine pollutant is not evident, the name is identified paren·
thetically in the shipping description. Environmentally hazardous substance, solid, n.o.s. (Zinc If a marine pollutant is not listed by name in the Hazar~ous bromide) (Marine Pollutant) Materials Table and it does not meet the defining criteria of
classes 1 through 8, its shipping description is either "Environmentally hazardous substance, liquid, n.o.s." or "Environmentally hazardous substance, solid, n.o.s.," as relevant
184 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders
- LE (SELECT PHRASES) rABLE 6.2 Information Required in Shipping Descriptions (continued) f'fJ,MP Q UN30B2, Enviro_ndmentdally h~zardous substances, liquid R , (sodium cyan, e an cupri c cyan ide), 9, PG 111 (Marin~ n-0 1 \ant) (Poison) pol u
T nsportation of a Hazardous Material on Wat . UNlll5, Ethylbenzene, 3, PG II (flashpoint = 15oC)
UNllg6, Battery fluid, acid, 8, PG II (IM DG Code 1 _ Acids)
sulk Transportation of a Hazardous Material by Railway
UNl962, Ethylene, compressed, 2.1, (DOT-113) (Do Not Hump or cut Off Car While in Motion) Placarded: FLAMMABLE GAS (HYDX11111)
UN2214, HOT Phthalic anhydride, 8, UN2214, 111, RQ (Maximum Operating Speed 15 mph) (LCTX111111)
UN1193, RESIDUE: Last contained et hyl methyl ketone, 3, PG 11 Placarded: FLAMMABLE (ACTX11111)
RQ, UN1076, Phosgene, 2.3, (8), (Poison - Inhalation Hazard, Zone A) Placarded: POISON GAS (DUPX11111 )9
RQ, UN1075, Liquefied petroleum gas, 2.1, (Noncorrosive) (CSXTl 111 11)9
Bulk Transportation of Anhydrous Ammonia by Highway
RQ, UN1005, Ammonia, anhydrous, 2.2, (0.2 percent water) (Inhalation Hazard)
RQ, UN1005 Ammonia, anhydrous, 2.2, (Not for Q and T tanks) (inhalation Hazard)
RELEVANT REGULATION
When a material designated with an n.o.s. entry in the Hazardous Materials Table is a marine pollutant, the names of at least two of the components most predominantly contributing to the marine pollutant designation are entered in parentheses in the shipping description .
When a hazardous material possesses a flashpoint equal to or less than 142°F (61°() and is transported on water, the flashpoint in degrees Celsius (closed cup) is entered with the shipping description.
When a hazardous material is designated with an n.o.s. entry in the Hazardous Materials Table and is not listed in section 3.1.4 ofthe IMDG Code/the applicable IMDG Code segregation group is entered with the shipping description.
The shipping description of a flammable gas or its residue contained within a DOT-113 rail tankcar contains an appropriate notation such as "DOT-113" and the statement "Do Not Hump or Cut Off Car While in Motion."
When DOT allows the transportation by ra ilroad of an elevated-temperature material pursuant to certain exceptions, the sh ipping description contains an appropriate notation such as "Maximum Operating Speed 15 mph."
The shipping description for the residue of a hazardous material contained in a rail tankcar must include the words "Residue: Last contained _____ (name of hazardous material in a rail tankcar before it was emptied)."
When hazardous materials are transported by rail, the accompanying shipping paper bears the notation "Placarded: ____ ~" in which the name of the placard displayed on the railcar is inserted.
When hazardous materials are transported by railway, the accompanying shipping paper lists the reporting mark and number9 displayed on the bulk packaging used for shipment.
When a carrier transports anhydrous ammonia having a water content equal to or greater than 0.2% by mass in a DOT Specification MC330 or MC331 tank truck, the shipping description includes "0.2 percent water" to indicate the suit- ability for shipping anhydrous ammonia in a cargo tank con- structed from quenched and tempered steel.
When a carrier transports anhydrous ammonia having a water content less than 0.2% by mass in a DOT Specification MC330 or MC331 tank truck, the shipping description includes the phrase " Not for Q and T tanks."
;The International Marit ime Dangerous Goods (IMDG) Code governs the vast majority of the shipments of hazardous materials by water. . See Section 3.7-A. DUPX and CSXT are the report ing marks of E. I du Pont de Nemours & Company and CSX Transportation Company, respectively.
(continued)
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 185
TABLE 6.2 Tf'ill:SW'illiW'\'IWi'911Wr'k ftl 112 a: a &,¥t.jij.j,i4j,jjijjiQ.1 ..... EXAMPLE (SELECT PHRASES) RELEVANT REGULATION
RQ, UN1005, Ammonia, anhydrous, 2.2, (0.2 percent water) (Inhalation Hazard)
When a carrier transports anhydrous ammonia or arn Sol utions relative density less than 0.880 at 15 deg, rnonia , .. . Id eesc· water, the shipping desmptIon me u es the words .. 1 h in tion Hazard" without either of the words "Poison" 0~ }la._ or the designation of a hazard zone. Toxic"
Bulk Transportation of Liquefied Petroleum Gas by Highway
UN1075, Liquefied petroleum gas, 2.1 (Noncorrosive) When a carrier transports liquefied petroleum gas in a 0 Specific~tio~ MC330 .?r MC331 t~n~ true.~. the shipping OT description includes Noncorrosive (or Noncor") to ind·
or
UN1075, Liquefied petroleum gas, 2.1 (Noncor) the suitability of transporting noncorrosive liquefied icate petroleum gas in a cargo tank made of quenched-and. tempered steel.
Bulk Transportation of Oil by Highway or Railroad UN1263, Paint-related material, 3, PG Ill (oil) When petroleum oil is transported in packaging having a
capacity of 3500 gal (13,250 L) or more, or when any oil is transported in packaging in a quantity of 42,000 gal (159,000 L) or more, the word "oil" is included on the shipping paper.
hazardous substance For purposes of DOT
regulations, a substance listed in Appendix A at 40 C.F.R. §172.101 in an amount that exceeds its reportable quantity and is transported in a sin- gle package
Let's consider another example. Suppose a fuel company desires to use a tank truck to move aviation gasoline from a petroleum storage facility to an airport terminal. DOT obligates the company to select the particular entry in the Hazardous Materials Table that most accurately describes the material to be transported. In this instance, the correct selec- tion is "Fuel, aviation, turbine engine." This combination of information is properly entered on a shipping paper as follows:
SHIPPING DESCRIPTION (IDENTIFICATION NUMBER, PROPER SHIPPING NAME, PRIMARY HAZARD CLASS OR DIVISION, SUBSIDIARY
UNITS HM HAZARD CLASS OR DIVISION, AND PACKING GROUP) 1 tank truck X UN1863, Fuel, aviation, turbine engine, 3, PG I
VOLUME (gal) 1500
When shippers offer aviation fuel for transportation, DOT requires them to enter only this description of the commodity on a shipping paper. The selection of any other name constitutes an illegal entry.
reportable quantity (RQl For purposes of 6.2-B REPORTABLE QUANTITIES DOT regulations, the On occasion, the letters RQ are entered with the shipping description of a hazardous amount listed at 40 material. "RQ" refers to the amount of a hazardous substance that constitutes a report· C.F. R. §
302 · 4
a nd 49
able quantity. For the purposes of the Superfund law(Section 1.3-D) any substance li5ted C.F.R. §172.101ofa , f "hazardous substance" at 40 C.F.R. §302.4 is a hazardous substance, regardless of the amount at issue; but or within the meaning of the purposes of the DOT regulations, only a substance listed at 49 C.F.R. § 1 ?2JOl, DOT and CERCLA, the Appendix A, in an amoun~ equal to or exceeding the reportable quantity is a hazard00'. release of which trig- substance. There are only five reportable quantities: 5000 lb (2270 kg)· 1000 lb (454 kg), gers mandatory notifi- , d us cation to the National lOO lb (45.4 kg); 10 lb (4.54 kg); and 1 lb (0.454 kg). Examples of several hazar 0 Response Center substances and their DOT reportable quantities are provided in Table 6.3. 186 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders
TABLE 6.3 Some Hazardous Sub Reportable Quantitie
stances and their s•
HAZARDOUS SUBSTANCE REPORTABLE QUANTITY
Acetone Acetonitrile Ammonia solutions Asbestos, whiteb
Barium cyanide cupric cyanide
Chlorine Chlorobenzene
Dichloromethane Ethyl methyl ketone
Hydrazine
Hydrogen fluoride, anhydrous
Hydrogen sulfide
Methyl isobutyl ketone
Methyl parathion
Nickel carbonyl
Nitric acid
Phosgene
Phosphine
Phosphorus
Phthalic anhydride
Sodium
Selenium disulfide
Sodium hydroxide
Sodium hypochlorite
Toluene
1, 1, 1-Trichloroethane
Xylene(s) '40 C.F.R, §302.4 and 49 C.F.R, §172.101, Appendix A, Table 1, bsection 10.19-A.
POUNDS KILOGRAMS 5000 2270 5000 2270 1000 454
1 0.454 10 4.54 10 4.54 10 4.54
100 45.4 1000 454 5000 2270
1 0.454 100 45.4
100 45.4 5000 2270
100 45.4
10 4.54
1000 454
10 4.54
100 45.4
1 0.454
5000 2270
10 4.54
10 4.54
1000 454
100 45.4
1000 454
1000 454
100 45.4
When a shipper intends to transport a hazardous substance in an amount equal to or greater than its reportable quantity, DOT requires "RQ" to be entered on the shipping paper either before or after its shipping description. Suppose, for instance, that a shipper intends to transport domestically by tank truck 4500 pounds of an aqueous ammonia solution containing 12% ammonia having a gross weight of 4500 pounds. Although four shipping descriptions for ammonia solutions are listed in Appendix C, the description having the identification number UN2672 most adequately describes the commodity,
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 187
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Unt o f an ammonia solution ex t an am o 4 k " ceed · Because the shipper intends to _cransbf; 6.3 as t000 p_o unds (45 g ), RQ" rnus/ ng the reportable quanti ty listed . in T~ er shipping descnpuon on the accompanying Wabe included either before or after ,t~, pr f, before the shipping d escnpnon, the complete sl/ b
ill If the shipper elects to enter RQ p. · d f II w s·
ping descripnon ,s note as o o
SHIPPING NAME, PRIMARY (IDENTIFICATION NUMBER, SUBSIDIARY HAZARD CLASS OR WEIGHT HAZARD CLASS OR Dl~IS~~~ PACKING GROUP) (lb)
UNITS HM DIVISIO , .
. olution (contains 12% ammonia ,n 4500
1 tank X RO, UN2672, Ammonia s
truck water), 8, PG 111 -- -----
SOLVED EXERCISE 6.1 . E. I. du Pont de Nemours & Company, l_nc. for transportation in a A shipper offers 2500 pounds of phosgene two h t shipping descript ion does DOT require on the shipping paper) ra il tankcar marked with the number 111 12. a . (DUCX is du Pont's reporting mark.) . ha ardous substance. From this knowledge and the informatio Solution: Table 6.3 indicates that phosgene 15 a z_ ws · n listed in Appendix c, the shipping description Is _p rov1deda _s __ 1_01_10 __ · ____________ _
SHIPPING DESCRIPTION (IDENTIFICATION NUMBER, PROPER SHIPPING NAME, PRIMARY HAZARD CLASS OR DIVISION, SUBSIDIARY HAZARD CLASS OR
DIVISION, AND PACKING GROUP) UNITS HM
WEIGHT (lb)
2500
1 cit X RO, UN1076, Phosgene, 2.3, (8), (Poison - Inhalation Hazard, Zone A) (Placarded: POISON"G,,A,.S,,) ,(.D,.U,.C •• X .. 11 ._ 1-.:1.=2:..) _ _ _ _________ _
SOLVED EXERCISE 6.2 The following shipping description of a hazardous material is provided on a transportation manifest:
SHIPPING DESCRIPTION (IDENTIFICATION NUMBER, PROPER SH IPPING NAME, PRIMARY HAZARD CLASS OR DIVISION, SUBSIDIARY HAZARD CLASS OR
UNITS HM DIVISION, AND PACKING GROUP) 1 tankcar X RO, NA3082, Hazardous waste liquid, n.o.s. (contains toluene and
xylene), 9, PG 111 (EPA ignitability) (UTLX42888)
WEIGHT (gal)
10,000
How is this shipping description useful to an emergency-response team? Solution: There are at least four pieces of information in this shipping description that are usefu l to emergency·
response personnel: The notation " RQ" informs first-on-the-scene responders that the commodity is a hazardous substance, the re- lease of which could adversely affect public health and the environment. The emergency-response crew should proceed to darn or dike the area to confine the leak and prevent its widespread release into the environment The reference to " EPA ignitability" indicates that the hazardous waste liquid exhibits the RCRA characteri~ic of ignitability (Section 3.2). This designation informs emergency-response personnel that the hazardous waS
t e
liquid possesses a flashpoint equal to or less than 140'F (60' C). Thus, it poses a risk of fire and explosion. Packing Group Ill indicates that the relative degree of hazard possessed by the commodity is minor. A minor degree of hazard means that although the material ignites, other groups of hazardous materials are far more hazardous- In Section 6.7, we shall note that identification numbers direct emergency-response personnel to certain recom· mended procedures for properly responding to an incident involving the release of th is hazardous waste liquid.
188 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders
6.2-C MARINE POLLUTANTS AND SEVERE MARINE POLLUTANTS DOT regulates the transportation of a variety of environmentally hazardous substances including marine pollutants and severe marine pollutants, or SMP. These are substances or mixtures that negatively impact aquatic life or tend ro bioaccumulate in seafood when released into a waterway. Protection of the marine environment is not an immediate man- date of DOT; nonetheless, DOT provides a listing of marine pollutants at 49 C. F.R. S 172. 101 , Appendix B, an excerpt of which is reproduced in Table 6.4.
Marine pollutants that potentially damage the marine environment more severely than others are called severe marine pollutants. In Table 6.4, severe marine pollutants are identified wi th the capital letters PP, meaning " pollution potential," in the column before their listing. The listed substances that are nor identified as severe marine pollutants a re referred to as marine pollutants.
When a substance or mixture is designated as a marine pollutant or severe marine pollutant, the words "Marine Pollutant" are included parenthetically with its shipping description. For example, when a glass bottle containing 10 pounds (4 .54 kg) of
pp
PP
PP
PP
PP
PP
PP
TABLE 6.4 Examples of Some Marine Pollutants and Severe Marine Pollutants•
MARINE POLLUTANT I MARINE POLLUTANT Anisole lsobutyl isobutyrate
I Barium cyanide lsobutyl propionate Butanedione Lead acetate Buty lbenzenes London purple Butyraldehyde I PP Mercuric oxide Cadm ium compounds pp Nickel carbonyl Carbon tetrachloride 1-Octanol Chlorine pp Phosphorus, white or yellow, dry,
under water, or in solution Cresols (o-, m-, p-) a-Pinene Cumene pp Polychlorinated biphenyls (PCBs) Cupric sulfate Propionaldehyde 1,3,5-Cyclododecatriene n-Propylbenzene Cymenes (o-, m-, p-) Sodium cyanide, solid or solution Dichlorobenzene (o-, m-, p-) Styrene monomer, inhibited Diethylbenzenes 1, 1,2,2-Tetrachloroethane
Epichlorohydrin Tetrachloroethylene
Ethyl acrylate, inhibited 1,3,5-Trimethylbenzene
Ferric arsenate Triethylbenzene
n-Heptaldehyde Turpentine
Hexachlorobutadiene n-Valeraldehyde
lsobutyraldehyde Xylenols
lsobutyl butyrate Zinc bromide a49 C.F.R. §172.101. Append ix B.
marine pollutant For purposes of DOT regu- lations, any substance denoted in Appendix B, 49 CF.R. §172. 101, and, when in a solut ion or mixture of one or more marine pollutants, is packaged in a concen- tration that equals or exceeds: (1) 10% by weight of the solution or mixture for materials identified in the appen- dix as marine pollut- ants; or (2) 1 % by w eight of the solution or mixture for mat erials identified in the appen- dix as severe marine pollutants
severe marine pollutants (SMP)
For purposes of DOT regulations, any substance denoted in Appendix B, 49 CF.R. §172.101, and indexed wtth the capital letters PP
Chapter se o 6 U f the DOT Hazardous Materials Regulations by Emergency Responders 189
dangerous-cargo mani- fest • For purposes of DOT regulations, a ship- ping paper that lists the hazardous materials stowed as cargo aboard watercraft and the spe- cific locations at which they are stowed
FIGURE 6.4 When the driver of a motor vehicle is at the vehicle's controls, DOT requires the shipping paper to be kept within immediate reach inside a holder mounted to the inside of the door on the driver's side of the vehicle.
mercury(Il) oxide is overpacked in a fiberboard ~ox and transported by Watercraft shipper conveys that the substance is a manne pollutant on the accornp 'the any1n dangerous-cargo manifest as follows: · g
SHIPPING DESCRIPTION (IDENTIFICATION NUMBER, PROPER SHIPPING NAME, PRIMARY HAZARD CLASS OR DIVISION, SUBSIDIARY HAZARD CLASS OR WEIG~T
_ ..:_U:_::N::_:IT..:S_ j....'..'.HM::.'..+----~ Dl:_:Vl::_Sl:.:O::.N,:.:.A.::.N:.::.D..:...PA:....C.:...K_IN_G_G_R_O_U_P)~~----+-(lb) Fiberboard x UN1641, Mercury oxide, 6.1, PG II (Marine Pollutant) (Toxic) 10 box (UN6G)
The dangerous-cargo manifest also lists the specific location at which the hazard · · f h d' d ous material 1s stowed aboard watercraft. When the na~e o t e commo ity oes not include
the name of the component that causes it to be a marine pollutant, DOT reqwres the shi . per to parenthetically identify the name of the component. An example is provided ln Table 6.2.
6.3 LOCATION OF THE SHIPPING PAPER DURING TRANSIT
During a transportation mishap, where may emergency-response personnel expect to locate the shipping paper? To avoid any confusion over its location, DOT requires the shipping paper to be carried on transport vehicles in a specific location. Because it is important to quickly locate this document when responding to incidents involving the release of a hazardous material, these requirements are briefly summarized next.
DOT requires the drivers of motor vehicles transporting hazardous materials and each carrier using the vehicles to clearly distinguish the appropriate shipping paper from other papers. When the driver is at the vehicle's controls, DOT requires the shipping paper to be within immediate reach and readily visible to any person entering the driver's compartment. For example, as shown in Figure 6.4, it may be stored in a holder mounted to the inside of the door on the driver's side of the motor vehicle. When the driver is not at the vehicle's controls, DOT requires the shipping paper to be located either in the holder or on the driver's seat inside the vehicle.
When hazardous materials are transported by railroad, DOT requires a member of the train crew, usually the conductor, to be in charge of the freight waybill that describes
190 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders
the wmignments that are transported. This . . ind1canng the pos1t1on in the tra· f herson also retains the consist, a document hazardous material. The consist usumllo. eac loaded and placarded car containing a
a Y 1s a comput · h 1· boxcar, and other transport vehicl er pnntout t at 1sts each cargo tank . e as a separate e t . d' d , of the tram, or alternatively in desc d. d n ry m ascen mg or er from the front
• . ' en mg or er from th f h · b · • • reporting mark (Secnon 3 7-A) and 1 d e rear o t e tram, y Its posmon, · , p acar . When hazardous materials are t .
carrier to provide a shipping paper d rans,_orte~ by ai~craft, DOT requires the aircraft The pilot usually retains the h • . escn mg t e consignment to the pilot in command. destination. s ipping paper m the cockpit until the plane reaches its
When hazardous materials are tra d b Prepare a dangerous-cargo m •f lnsporte Y watercraft, DOT requires the carrier to am est, 1st or stowag ) d b · · h f the vessel. This document must be co '. . . e P an an su mlt 1t to t e master o vessel's bridge. On barges it · k . ntamed withm a designated holder on or near the
' is ept m the pilot house of the tugboat.
6.4 DOT LABELING REQUIREMENTS In most instances involving the transportatio of h d · I O · h' t ff 'b d n a azar ous matena , D T requires
s ippers O a ix prescn e warning labels corresponding to the primary and subsidiary hazard classes of the material directly to the outs'd f f h k · Th · d 1 b 1 'd . . 1 e sur aces o t e pac agmg. e require a _e_ s are I entifted by the code entries in column 6 of the Hazardous Materials Table. Add1t1onal labeling requirements for hazard classes 1 and 7 are provided in Semons 15.4-D and 16.10-B, respectively.
. The DOT labels that shippers affix to packaging containing a hazardous material are displayed m Figure 6.5 and their names are listed in Table 6.5. Each label is diamond- sha_ped and color-c~ded to s_ignify a specific hazard class or division and may also include a pictograph to rapidly s1gmfy the potential hazards of the contents. Each label also bears the hazard class or division number in its lower corner.
Two points regarding the nature of the EXPLOSIVE labels should be noted:
The uppercase letters that follow the division numbers for the EXPLOSIVE labels designate the compatibility groups of explosives, whose characteristics are discussed in Section 15.4-B. The label at the far right of Hazard Class 1 is the EXPLOSIVE subsidiary label. It is affixed to packaging when the code listed in column 6 of the Hazardous Materials Table indicates that the hazardous material has an explosive subsidiary hazard.
DOT requires shippers and carriers to affix the specified labels on the surface of the package near the spot where they indicate the proper shipping name. For instance, when shippers and carriers transport gasoline in drums, DOT requires them to affix the FLAMMABLE LIQUID label to the outside surface of each drum adjacent to the spot where it is marked "Gasoline."
When cylinders or other packages have irregular surfaces on which labels cannot be satisfactorily affixed, DOT allows the labels to be secured on a tag, unless the packages contain radioactive materials. Because of the irregularity of their surfaces, gas cylinders are labeled on shoulder tags like that shown in Figure 6.6. When the tags are embossed on the cylinders, OSHNGHS hazard and precautionary statements may be cited along with the posting of the relevant transportation pictograms, or DOT labels.
DOT also requires shippers to affix duplicate labels corresponding to their applica- ble codes to certain packaging types. Duplicate labels are displayed on at least two sides or two ends other than the bottom. For multiunit car tanks, they are displayed on each
consist A shipping document that lists the location of one or more locomotives coupled to one or more railcars loaded with hazardous materials as they are placed, one by one, in a train, sometimes from the rear forward
label For purposes of DOT regulations, any of several diamond- shaped and color-coded warning signs, with or without a pictogram, affixed on the packages of hazardous materials to identify the specific hazard class or division of their contents
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 191
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EXPLOSIVES 1.1 EXPLOSIVES 1.2 EXPLOSIVES 1.3 EXPLOSIVES 1.4 EXPLOSIVES 1.5 EXPLOSIVES 1.S HAZARD CLASS 3
HAZARD CLASS 2
· · ~ FLAMMABLE NON-FLAMMABLE POISON GAS FLAMMABLE GAS GAS HAZARD CLASS 4 HAZARD CLASS 5
··· ~ FLAMMABLE SPONTANEOUSLY DANGEROUS OXIDIZER SOLID COMBUSTIBLE WHEN WET ORGANIC PEROXIDE HAZARD CLASS 6
POISON INHALATION POISON INFECTIOUS HAZARD SUBSTANCE
HAZARD CLASS 7
RADIOACTIVE WHITE-I
HAZARD CLASS 8
RADIOACTIVE YELLOW-II
RADIOACTIVE YELLOW-Ill
- 1
FISSILE
HAZARD CLASS 9
CLASS 9
FIGURE 6 .5 DOT requires sh ippers to affix warning labels that identify the rimar . . ·al on the exterior surface of its packaging. The asterisks in the orange EXPLOSIVE i b I Y and subsidiary hazard classes of a hazardous rnaten 8 01 left blank 1f the explosive hazard is the subsidiary risk associated with the ro~ue; are replaced by the compatibility group (Section 1 SA· ), words (not shown here on label due to space constraints): "In case of D p · The INFECTIOUS SUBSTANCE label bears the folloWln9 USA
CORROSIVE
Notify Director CDC, Atlanta, GA (800) 232-0124." amage or Leakage, Immediately Notify Public Health Authority. In
192 Chapter 6 Use of the DOT Hazardous Materials Regulation b s Y Emergency Responders
TABLE 6.5 DOT Warning Labelsa
HAZARD CLASS HAZARD CLASS OR DIVISION LABEL NAME OR DIVISION
LABEL NAME
EXPLOSIVE 1.1 5.1 OXIDIZER 1.1 EXPLOSIVE 1.2 5.2 ORGANIC PEROXIDE 1.2 - EXPLOSIVE 1.3 6.1 (Inhalation hazard, POISON INHALATION HAZARD 1.3 Zone A or B) - EXPLOSIVE 1.4 6.1 (other than inhalation POISON 1.4
hazard, Zone A or B) - EXPLOSIVE 1.5 INFECTIOUS SUBSTANCE 1.5 6.2 1.6 EXPLOSIVE 1.6 7
RADIOACTIVE WHITE-I
2.1 FLAMMABLE GAS 7 RADIOACTIVE YELLOW-II
2.2 NON-FLAMMABLE GAS 7 RADIOACTIVE YELLOW-Ill
2.3 POISON GAS 7 (fissile material) FISSILE
3 FLAMMABLE LIQUID 7 (empty packages)b EMPTY
4.1 FLAMMABLE SOLID 8 CORROSIVE
4.2
4.3 149 C.F.R. §172.400. bsectlon 16.10-B.
SPONTANEOUSLY COMBUSTIBLE
DANGEROUS WHEN WET
9 CLASS 9
end. For a freight container or aircraft unit load device, they are displayed on or near the closure. The regulations pertaining to use of duplica te labels are published at 49 C.F.R. §172.406.
When shippers offer for transportation packages containing hazardous materials authorized solely for transport on cargo aircraft, or when the packages contain net quan- tities that exceed those a uthorized on passenger-carrying aircraft, DOT requires them at 49 C.F.R. § 172.448 to display the CARGO AJRCRAFT ONLY label in Figure 6. 7 in addition to any other required labels .
FIGURE 6.6 At 49 C.F.R. § 172.406(b)(2), DOT allows the use of tags to provide both marking and label ing infor- mation when they are affixed to.the surface of gas cylinders. As required by OSHA/GHS, hazard and precaution- ary s_tatements are provided on the left of this shoulder tag and the transportation pictogram (or DOT label) is provi ded on the right. This particular tag is permanently affixed to the outside surface of a propane cylinder. This shoulder tag provides the required marking information on the left and the warn ing label on the right .
cargo aircraft An air-transport vehicle designed solely to transport cargo but not paying passengers
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 193
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448 DOT requ ires FIGURE 6 .7 At 49 C.F.R. §l;~RCRAFT ONLY label to shippers to affix the CARG~ d us material packag- the exterior surface of the azar o ed on ing when its transportation is solely ~~p~~\he hazard- board cargo aircraft or the net quant1 _Y n passen- ous material approved for transportat10~ on the
er-carrying aircraft is exceeded. The printing n e ~ARGO AIRCRAFT ONLY label is black on an ora g
background .
GO AIRCR
SOLVED EXERCISE 6.3 ff h of five fiberboard boxes that contain eight
marking (mark) For purposes of DOT regu- lations, a descriptive name, identification number, instructions, caution, weight, specifi- cation, "UN" marks, or any combination thereof required on outer packaging of hazardous materials
Identify the label(s). if any, that DOT requ ires a shipper to a ,x to eacder w ater. 1-pound bottles of solid white elemental phosphorus submerged un . dix c w e determine t hat the label codes for white Solution: By reference to the entry in column 6 of App~n I rh entries mean that DOT requires the shipper elemental phosphorus under water are 4.2 and 6-1, respective y. h es~ ·or surface of each fiberboard box. These to affix SPONTANEOUSLY COMBUSTIBLE and POISON labels on t e e en ther than the bottoms) of each box labels must appear side by side on the surface of two of the sides or ends (o ·
6.5 DOT MARKING REQUIREMENTS DOT requires several markings, or marks, to be written o~ affixed on packaging contain- ing a hazardous material when it is offered for transportation. Some markings are written precautionary statements like the expressions "!NHALATI~N HAZARD" or "MOL- TEN ALUMINUM"; other markings resemble labels with p1ctograms with or without written precautionary statements.
There are rwo general types of these markings. The first type, called the specification marking, is provided by the manufacturer of the packaging. In compliance with DOT regu- lations, the manufacturer marks certain information on packaging before it is used by ship- pers or carriers. It usually consists of professionally printed information on an outer exterior surface of the packaging indicating that the packaging was constructed and tested in compliance with applicable DOT specifications and standards. The specification mark- ing also includes the name and address or symbol of the packaging manufacturer or approval agency and the letters and numerals that identify the standard or specification, DOT's requirements relating to specification marking for gases transported in cylinders and rail tankcars were previously reviewed in Sections 3.3-B and 3,7-A, respectively.
The second type of marking requires shippers and carriers of hazardous materials to legibly mark certain other information on an outer exterior surface of the packaging used for shipment. These markings are written in English and are displayed on the pack- aging, unobstructed by the presence of labels, advertising, and other information. In particular, DOT requi~es shippers to mark on an outer exterior surface of nonbulk pack- aging certain informauon published at 49 C.F.R. § 172,301. This information consists of the ~ame _and address of the shipper and receiver and the proper shipping name and UNI NA 1dent1ficat1on number of the hazardous material When the p h ' · me in the hazardous materials table is designated by an n s entry DOroTper s _ippinhg_ na s to · · · , requires s 1pper
194 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders
mark the outer exterior su f . h . r ace of the k . m parent eses immediately folio . Pac aging with the tech .
Some commonly encounr dwmg or below the prope hi meal name of the material hazardous materials are pro e~e d DOT marking requirem r s f Pmg _name. through 6.5-M, and Sections ~'5 eO in the sections that im;n~~
0 ~ s~ippers and carriers of bulk packaging, respectively s· - . \hrough 6.5-W address th: ;ate_y allow. Sections 6.5-A divisions 1, 6.2, and 7 are n~re~~c,a marking requirements app~qu~tmen~s for nonbuJk and
ater, in Sections 15.4-D 10 2 ca e to azard classes and ' · l-D, and 16.10-C, respectively 6.5-A MARKING NONBULK .
PERFORMANCE TEST PFAE CKAGING TO DENOTE . . ATURES In comphance with global ha . .
49 C FR § 178 503 rmomzation (Secti 1 9) . : · · · to provide the followin on · ' DOT requires manufacturers at mgs m the presemed sequence on nonbuJk g performance-oriented specification mark- solid hazardous materials: outer packaging used to transport liquid and
The "un" mark shown in th 1 f . . h' . I e e t margm (the lo I Wit ma circ e) or the capital let UN wercase etters u and n inscribed A k . 'd ters ,
pac agmg I entification code designatin th from which It was constructed Th· d . g e type of package and the material letter, and second number in th: Is co e IS a combination of a first number capital 0 f 15 sequence Their si · f · • ' ne o the capital letters X y z h. . gm Icance JS provided in Table 6.6. dard for which the packagi~g ~o: 'eac fuolflwh,ch designates the performance stan-
a success Y tested as follows· X For packages meeting PG I, PG II, and PG III res;, . Y For packages meeting PG II and PG III tests Z For packages meeting PG IJJ tests only A designation of t_he spe~ific gravity of liquids, or the mass in kilograms of solids for which the packaging design has be~n successfully tested without an inner lining ' The lette~ S ~or smgle and composite packaging intended to contain liquids, the rest pressure m kilopascals rounded to the nearest 1 O kilopascals of the hydrostatic pres- ~ure test that the_ pack_aging design type has successfully passed, and for packages intended to contam sohds or inner packagings The last two digits of the year during which the package was manufactured The letters USA indicating that the package was marked pursuant to DOT's standards The symbol and identification number of the manufacturer
When the packaging and its contents weigh more than 66 pounds (30 kg), the mark- ings are applied on an exterior surface of the top and a side of the packaging; otherwise they appear on the bottom of the packaging. They may be applied on a single line or mul- tiple lines, and slash marks are generally used to separate the information into sections. Examples of these markings are provided in Figure 6.8.
Suppose 110 pounds (50 kg) of cupric cyanide is transported within several glass bottles that are individually cushioned in a fiberboard box. DOT requires the specifica- tion markings shown in Figure 6.9 to be embossed on an exterior surface of the box, the majority of which are provided by its manufacturer.
6.5-B MARKING CYLINDERS CONTAINING COMPRESSED GASES AND LIQUEFIED COMPRESSED GASES
We noted in Section 3.3-B that DOT requires gas cylinders to be marked so as to identify their service pressures. Jn addition, DOT requires_ gas cylinder~ to be periodically_ tested and retested to determine their mechamcal mtegnty by authonzed _per~ons. As wah the service pressures, the results of these testing activities and the 1dent1hcat10n number of the tester and retester must be marked on the outside surfaces of the cylinders.
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders ' 195 j
i!&ii-MH&i-1rwrw:r::w-2m1nw:rear:w:r: · · TABLE 6.6 CODEA.b MEANING
CODE MEANING woven plastic bag, water-resistant -
1A1 Steel drum, nonremovable head SH3 -
1A2 Steel drum, removable head SH4 Plastic film bag
Textile bag, unlined or noncoated -
1B1 Aluminum drum, nonremovable head SL 1 -
1B2 Aluminum drum, removable head SL2 Textile bag, silt-proof
1D Plywood drum SL3
Paper bag, water-resistant - 1G Fiber drum
SM1 Paper bag, multiwall
1H1 Plastic drum, nonremovable head SM2
Paper bag, multiwall water-resistant
1H2 Plastic drum, removable head 6HA1
Plastic receptacle within a protective steel drum
1N1 Metal drum, nonremovable head 6HA2
Plastic receptacle within a protective steel crate or box
1N2 Metal drum, removabale head 6HB1
Plastic receptacle within a protective aluminum drum
2C1 Wooden barrel, bung type 6HB2 Plastic receptacle within a protective aluminum crate or
box
2Q Wooden barrel, slack type, removable head 6HC Plastic receptacle within a protective wooden box
3A1 Steel jerrican, nonremovable head 6HD1 Plastic receptacle within a protective plywood drum
3A2 Steel jerrican, removable head 6HD2 Plastic receptacle within a protective plywood box
3B1 Aluminum jerrican, nonremovable head 6HG1 Plastic receptacle within a protective fiber drum
3B2 Aluminum jerrican, removable head 6HG2 Plastic receptacle within a protective fiberboard box
3H1 Plastic jerrican, nonremovable head 6HH1 Plastic receptacle within a protective plastic drum
3H2 Plastic jerrican, removable head 6HH2 Plastic receptacle within a protective plastic box
4A Steel box 6PA1 Glass, porcelain, or stoneware receptacles within a protective steel drum
4B Aluminum box 6PA2 Glass, porcelain, or stoneware receptacles w ithin a protective steel crate or box
4C1 Wooden box, ordinary 6PB1 Glass, porcelain, or stoneware receptacles within a protective aluminum drum
4Q Wooden box, silt•proof walls 6PB2 Glass, porcelain, or stoneware receptacles within a protective aluminum crate or box
4D Plywood box 6PC Glass, porcelain, or stoneware receptacles within a
protective wooden box
4F Reconstituted wooden box 6PD1 Glass, porcelain, or stoneware receptacles within a
protective plywood drum
4G Fiberboard box 6PD2 Glass, porcelain, or stoneware receptacles within a protective wickerwork hamper
4H1 Plastic box, expanded 6PG1 Glass, porcelain, or stoneware receptacles within a protective fiber drum
4H2 Plastic box, solid 6PG2 Glass, porcelain, or stoneware receptacles within a protective fiberboard box
SH1 Woven plastic bag, unlined or uncoated 6PH1 GlasS, P?rcelain, or stoneware receptacles within a protective expanded plastic packaging
SH2 Woven plastic bag, silt•proof 6PH2 Glass, P?rcela!n, or stoneware receptacles w ithin a protective solid plastic packaging
' 49 c.F.R. §§178.504-178.521. b49 C.F.R. §§178.522 and 178.523.
196 ency esponders Chapter 6 Use of the DOT Hazardous Materials Regulations by Emerg R
1 = Drum A= Steel 1 = Tighthead
Year of Manufacture
Specific Gravity of Liquid Manufacturer's DOT Registration Number
Packing Group
Packing Group
(ROI COPPER CYANIDE UN1587
(al
(bl
From: ___ _ (ii) 4G/Y50/S/09/USA/RA To:
Country of Manufacture
Manufacturer's DOT Registration Number
Country of Manufacture
FIGURE 6.9 This outer package is a fiberboard box used as PG II packaging for transporting glass bottles con- taining copper cyanide, the proper shipping name for cupric cyanide. "RO" must be included with the proper shipping name, because the reportable quantity for th is commodity is 10 pounds. "4G" is provided in Table 6.6 as the UN identification code for a fiberboard box; "Y" designates the performance standard to determine whether the box retained its integrity when 50 kilograms of material was contained therein and subjected to packaging performance tests for Packing Group II; "S" designates that cupric cyanide is a solid; "09" means the box was manufactured in 2009; and "USA/RA" designates that the box was manufactured in the United States and marked pursuant to DOT standards by "RA, " the symbol of the box's manufacturer. DOT also requires the shipper to affix the MARINE POLLUTANT mark and POISON labels to the box.
FIGURE 6 .8 Examples of package identification markings embossed on (a) a steel tighthead drum containing a liqu id chemical product and (b) an openhead plastic drum containing a solid chemical product.
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 197
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limited quantity (Ltd Qty) For purposes of DOT regulations, the maximum amount of a specific hazardous material for which there may be labeling or packaging exceptions
6.5-C MARKING NONBULK PACKAGING CONTAINING HAZARDOUS SUBSTANCES
When shippers transport a hazardous substance in nonbulk packaging in an amount h exceeds its reportable quantity DOT requires them to mark the outer exterior surf
I at
the packaging with the letters' RQ in _associ~tion_ with the proper shipping name. teth! proper shipping name does not specifically 1dent1fy the hazardous substance, DOT I requires them to indicate the name of the hazardous substance on the packaging in pa a so theses in association with the proper shipping nam~- If more t~an. one hazardous :~~: stance is contained within the packaging, DOT reqmre~ _them to indicate at lease the two hazardous substances with the lowest reportable quannnes.
6.5-D MARKING NONBULK PACKAGING CONTAINING HAZARDOUS MATERIALS THAT POSE AN INHALATION HAZARD
When shippers offer for transportation in nonbulk packaging a hazardous material tha poses a health hazard by inhalation, DOT requires them at 49 C.F.R: § 172.102.13 1; mark "INHALATION HAZARD" in association with the proper shipping name and identification number.
INHALATION HAZARD
6 .5-E MARKING NONBULK PACKAGING CONTAINING CLASS 6 HAZARDOUS MATERIALS
When a poisonous material is transported within nonbulk plastic packaging, DOT requires shippers to permanently mark the packaging with the word "POISON."
POISON
6 .5-F MARKING NONBULK PACKAGING CONTAINING LIQUID HAZARDOUS MATERIALS OTHER THAN LIQUEFIED COMPRESSED GASES
When shippers transport liquid hazardous materials other than liquefied compressed gases in nonbulk packaging, DOT requires them at 49 C.F.R. § 172.312 to assure that the closure is upward, and that the packages are marked with package orientation markings on the outer exterior surface of the packaging on two opposing sides with arrows point- ing in the correct upright direction, as shown in the following illustration:
THIS END UP
tt 6.5-G MARKING NONBULK PACKAGING CONTAINING A LIMITED
QUANTITY OF A HAZARDOUS MATERIAL FOR SHIPMENT BY RAIL OR AIR
DOT authorizes the transportation of certain hazardous materials in a limited quaotitY {Ltd Qty) by passenger-carrying aircraft, rail, or cargo aircraft. DOT provides this auth0- rization in column (9) of the Hazardous Materials Table published at 49 C.F.R. §172JOl,
198 Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders
When the tramportation of a hazardous material is authorized in a limited quantity by rail, DOT requ1res the shipper at 49 C.F.R. §172.315 to mark its package on at least one side and one e_nd a~ show~ on the left below. When the transportation of a hazardous material 1s authorized m a hm1ted quantity by passenger-carrying or cargo aircraft, DOT requires them to mark the package on at least one side and one end as shown on the right.
The top and bottom triangular portions of both markings, their borders, and the let- ter Y are black and their centers are white.
6.S·H MARKING NONBULK PACKAGING REQUIRING A SPECIAL PERMIT When DOT assigns a special permit to a shipper to containerize a hazardous material in an unconventional fashion, it requires the shipper to mark the packaging with the nota- tion "DOT-SP-" followed by the assigned special permit number.
6.5·1 MARKING NONBULK PACKAGING CONTAINING HAZARDOUS WASTES
When an RCRA-regulated hazardous waste (Section 1.3-C) is transported in containers hav- ing a capacity of 119 gallons (450 L) or less, EPA requires the hazardous waste generator to affix the HAZARDOUS WASTE marking in Figure 6.10 on an outer surface of the containers.
6.5-J MARKING NONBULK PACKAGING OF MARINE POLLUTANTS OR SEVERE MARINE POLLUTANTS
When shippers intend to transport a marine pollutant or severe marine pollutant by water- craft in nonbulk packaging, DOT requires them to affix the marine pollutant mark shown in Figure 6.11 on an outer exterior surface of the packaging along with the following information:
I When the proper shipping name does not specifically identify the name of the marine pollutant, DOT requires them to indicate the name on the packaging in parentheses in association with the proper shipping name.
HAZARDo_u_s_1 WASTE
STATE & FEDERAL LAW PROHIBITS IMPROPER DISPOSAL. IF FOUND, CONTACT THE NEAREST POLICE OR PUBLIC SAFETY
I AUTHORITY OR THEUS. ENVIRONMENTAL PROTECTION AGENCY I OR THE CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCE/$ CONTROL
GENERATOR INFORMATION:
:~~!es_s __ -_-_-_-_-_-_-_-_-::._-::._-_-_-_-_-_-_-:-c--cPHON=::-, ========== CITY _________ STATE_ ZIP ____ _
I ~~o./~~NO. --------------1 EPA CA. ACCUMUI.ATION WASTE NO. ____ WASTE NO. ___ START DATE ___ _ I CONTENTS COMPOSmON PHYSICAL STATE I HAZARDOUS PROPERTIES D FLAMMABLE TOXIC I SOLID D LIQUID D CORROSIVE D REACTIVITY D OTHER ---- 1, [
I HANDLE WITH CARE! .._ ___ co_NTAINSHAZAR-~oo-u.s .. o_R_TOXI __ C~-
FIGURE 6 .10 When a container having a capac- ity of 119 gallons (450 L) or less is used to transport hazardous wastes (Sec- tion 1.3-C), DOT and EPA require their generators at 40 C.F.R. §262.32 to affix this HAZARDOUS WASTE marking on the containers together with the genera- tor's name and address and the relevant manifest number.
Chapter 6 Use of the DOT Hazardous Materials Regulations by Emergency Responders 199
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