By Prokopis A. Christou, PE
The Research & Special Programs Administration (RSPA), an agency of the U.S. Department of Transportation (DOT), revised the Hazardous Materials regulations (HMR) to maintain alignment with international standards (the United Nations Recommendations, the International Maritime Dangerous Goods Code, and the International Civil Aviation Organization's Technical Instructions). What in the U.S. we refer to as hazardous materials, the rest of the world calls dangerous goods.
This final rule incorporated various changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations and vessel stowage requirements. In addition, it revised the requirements for intermediate bulk containers and UN portable tanks for alignment with international requirements. Following is a partial list of these changes:
The word "Inhibited" was replaced by "Stabilized" where it appeared in DOT Proper Shipping Names listed in the Hazardous Materials Table. This means that shipping descriptions and markings must reflect the revised DOT Proper shipping names. A transition period is provided until October 1, 2005 to switch to the revised shipping names.
The requirement to distinguish between primary and subsidiary labels was removed. According to the HMR, DOT labels must be affixed on packages for subsidiary hazard in addition to the primary hazards for certain materials. Under the current regulation, the DOT label for the primary hazard must display the appropriate Class number or Division number on the bottom corner of the label, but the label for the subsidiary hazard must not display it. Under the change, the label for the subsidiary hazard will be the same as the one for the primary hazard. RSPA believes that this change will enhance safety and hazard communication, and will eliminate the need for shippers to stock two sets of labels. For domestic shipments by highway and rail, the old style subsidiary labels may continue to be used until October 1, 2005 when the new requirement becomes mandatory.
The requirement to distinguish between primary and subsidiary placards is also eliminated. Under the change, the DOT placard for the subsidiary hazard will be the same as the one for the primary hazard. For domestic shipments by highway and rail, the old style subsidiary placards may continue to be used until October 1, 2005 when the new requirement becomes mandatory.
The requirements for shipping samples were revised. The HMR allows shipping samples of certain material for which the hazard class is uncertain and must be determined by testing. These materials can be assigned a tentative Proper Shipping Name, Hazard Class, and Identification Number. Under the change, these materials and hazardous waste samples must now include the word "sample" in association with the DOT Basic Shipping Description, they require combination packaging, the packaging size must not exceed 2.5 Kg (5.5 pounds) per package, and the technical names are not required. This requirement does not apply to "product samples" (small quantities of products) often shipped to customers for evaluation because these materials have already been classified, i.e. they are not "samples". This requirement applies to environmental samples for which the hazard class is uncertain and must be determined by testing. For example, the DOT shipping description for a liquid sample tentatively classified as flammable liquid, packing group III would be: FLAMMABLE LIQUIDS, N.O.S., 3, UN1993, PG III, SAMPLE.
The words "SOLID", "LIQUID", or "MOLTEN" may be added to Proper Shipping Names as applicable (optional).
Several changes, including deletions, were made to the list of Marine Pollutants.
Shippers and carriers of hazardous materials and , and package manufactures may want to review the final rule for a complete list of changes that affect their activities.
The rule effective 10/1/01. Mandatory compliance is delayed until 10/1/02. Some transition dates are provided.
More information
Federal Register: June 26, 2001, Page 33316
U.S. DOT Regulation: 49 CFR 171 et al.
Hazmat 101 News archives: http://www.hazmat101.com
About the Author
Prokopis Christou, P.E. has 14 years of diverse experience in managerial,
technical, and teaching responsibilities in environmental, safety,
transportation, regulatory, and engineering matters. Email: prokopis@hotmail.com