Shipping Hazardous Materials by Ground Part 1. General

Copyright 2017, Halfday Hazmat Training. Not to be reproduced without permission. | Part 1. General Awareness and Familiarization

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Shipping Hazardous Materials by Ground

Part 1. General Awareness and Familiarization

The authority in the United States:

The US Department of Transportation, DOT, is the authority in the United States. They are responsible for developing, issuing and enforcing the hazardous materials regulations. DOT’s primary safety goal is to reduce the risks posed by the transportation of hazardous materials. If Hazmat is shipped illegally, the DOT can issue fines or even jail time.

What is Hazmat? Hazardous materials are substances or materials that can burn, explode, react violently or cause injury or harm to people, property or the environment when transported in commerce.


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Hazard Classes are listed and defined in the 49 CFR 173 Subpart D. They include:

Class 1: Explosives. It is divided into 6 divisions.

Class 2: Gases. Class 2 is broken down into three divisions.

Division 2.1 is flammable gas

Division 2.2 is non-flammable compressed gas

Division 2.3 is poisonous gas


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Class 3: Flammable and combustible liquids. Class 3 materials and their vapors are highly flammable.

Class 4 is divided into three divisions.

Division 4.1 is flammable solids

Division 4.2 Spontaneously combustible materials

Division 4.3 dangerous when wet materials

Class 5 is divided into 2 divisions.

Division 5.1 oxidizers generally yield oxygen readily and cause or contribute to combustion of other materials.

Division 5.2 organic peroxide include materials which may be thermally unstable compounds. Under certain conditions an organic peroxide can again to chemically decompose by itself producing heat or combustion.


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Class 6 is divided into 2 divisions:

Division 6.1 poisonous or toxic materials. Poisons may cause injuries, even death if swallowed, inhaled or absorbed through the skin.

Division 6.2 infectious substances. Infectious substances included microorganisms and regulated medical waste that may cause disease in humans and animals.

Class 7: Radioactive material. Radioactive materials emit ionizing radiation that may be harmful to humans or animals and can affect photographic and x-ray film.

Class 8: Corrosives. Corrosive materials cause damage when they come in contact with living tissue, aluminum or steel.


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Class 9: Miscellaneous Hazardous Materials. These are any materials that may pose a risk to health safety and property which are not covered in other hazard classes. Class 9 includes environmentally hazardous substances, hazardous waste and marine pollutant.

Hazmat comes in many shapes and sizes. In addition to the industrial products that we immediately think of, there are many consumer goods like cosmetics, paints, aerosols, medicines, etc.


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Who is a Hazmat Employee? A hazmat employee is anyone who:

● Load, unload, or handle hazardous materials;

● Design, manufacture, fabricate, inspect, mark, etc. containers or packaging component that isused in transporting hazmat in commerce;

● Prepare hazmat for transportation;

● Are responsible for the safety of transporting hazmat; or

● Operate a vehicle used to transport hazmat

Copyright 2017, Halfday Hazmat Training. Not to be reproduced without permission. | Part 2. Safety

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Part 2. Safety

OSHA – Occupational Safety and Health Administration – regulation body for Employee Safety in the US.

OSHA’s Hazard Communication Standard is based on the United Nations Globally Harmonized System, and effects the format of Safety Data Sheets, and labelling criteria for product labels. The HCS was introduced in 2012, and became mandatory in 2015.

The SDS replaces what used to be called a MSDS (Material Safety Data Sheet). It has the following 16 sections: (1-16) All contain important information, but hazmat shippers should pay special attention to the blue sections below.


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Pictograms are the visual representation of the hazard found in a material. OSHA pictograms do not replace the need for DOT Hazard Labels – Both are used.


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Pictograms are placed on the immediate container of a hazardous material (use the bottle).

Hazard Labels are place on the exterior of packages offered for transportation (use the box).

Both should be placed on UN Approved Single Packages like the drum shown below (use the drum).

Pictograms:


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Product Label –

1. Product Identifier matches the identifier on the SDS2. Signal Word will either be “Danger for severe hazards or “Warning for less severe hazards3. Hazard Statements describe the nature of the hazards posed by the material4. Precautionary Statements recommend measures to prevent or minimize that bad stuff that

might happen as a result of exposure

5. Supplier Identification gives contact information for the manufacturer or supplier of thematerial, and includes the phone number

6. Pictograms

Copyright 2017, Halfday Hazmat Training. Not to be reproduced without permission. | Part 3. Security + In-Depth Security

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Part 3. Security + In-Depth Security This training is NOT a substitute for the training that you will need on the specific Security Plan developed by your employer.

Your employer is required by the Department of Transportation (DOT) to have a security plan.

The plan needs to cover possible transportation security threats and detail measures to address those threats. The plan must include the following elements:

– Personnel security: This has to do with hiring practices... background checks etc.– Unauthorized access: Just like to it sounds, this has to do with who can access and what kind of

security; gates, badges, locks etc. are used to limit access.– En-route security: This covers how the hazmat is kept secure as it moves from point A to point B.


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STORING HAZARDOUS MATERIALS ONSITE

• Hazardous materials onsite should be lockable in storage rooms, fenced-in areas or separate, high-security buildings.• Valves on tanks and storage vats should be secured as well.• Using a sign out system for keys to restricted areas and performing frequent inspections to make surethat no one has tampered with locks or other security equipment can also help.

INCOMING SHIPMENT SECURITY • Security doesn’t end once hazardous materials arrive at their destination. If a delivery is not expected,the carrier that sent them should be immediately contacted to verify that the shipment is legitimate.• Before a shipment is unloaded, its shipping papers must be checked and the vehicle and its cargothoroughly inspected.• Containers should be closely examined for signs of damage and tampering. Workers should also be onthe lookout for any unusual containers as well as containers that are improperly labeled or that don’tmatch the description in the shipping papers.• Special attention should be given to shipments that enter the United States from other countries,since there might not have been much security at their points of origin. If the origins of a container arequestionable or it is damaged in any way, it should be refused.• Any evidence of tampering or theft should be reported to management so that they can contactlaw enforcement.• Warehouse doors should be closed immediately after a shipment has been unloaded.


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RED FLAGS

So what kind of things should you be looking out for? ● Anyone, fellow employee, contractor or visitor who shows an unusual amount of interest in the

hazardous materials stored at your facility or who is in a restricted area without properclearances.

● Any sign of damage or tampering on containers, packaging or vehicles● Anyone who tries to draw you into conversation about the hazmat that you’re carrying or

storing● Drivers should also pay attention to who is receiving their shipment, especially new customers.● Last minute shipments that require rush processing● A customer’s lack of knowledge about the proper use of a material● Apparent stockpiles of other shipments of hazardous materials, especially materials that are not

normally used together● Refusal to sign for a shipment or to show photo identification● An offer of a cash payment or bribe to deliver a shipment.

Copyright 2017, Halfday Hazmat Training. Not to be reproduced without permission. | Part 4. Function Specific Training – 49 CFR

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Part 4. Function Specific Training – 49 CFR

This is where regulations dealing with ALL types and modes of transportation are located. In this Course we will focus on the Hazardous Materials Regulations, or HMR which is contained in Parts 171-180.

Part 171 - General Information, regulations, and definitions Part 172 - Hazardous Materials Table, Special Provisions, Hazardous Material Communications, Emergency Response Information, Training Requirements and Security Plans Part 173 - Shippers - General requirements for shipments and packagings Part 174 - Carriage by Rail Part 175 - Carriage by Aircraft Part 176 - Carriage by Vessel Part 177 - Carriage by Public Highway Part 178 - Specifications for Packagings Part 179 - Specifications for Tank Cars Part 180 - Continuing Qualification and maintenance of packaging

Each of the Parts listed above begins with a table of contents that lists the Sub-parts and Sections in the pages that follow.


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Important Terms – defined / explained:

● Types of Packagings● Packing Group● Shipment Size● Segregation Table

Types of Packagings: Shipments can be prepared in a variety of Packaging Types. Four common types of Packagings include:

• Single Package: dangerous goods are placed directly into a UN Approved or DOT Certifiedcontainer

o Ex: drums, cylinders, and jerricans

• Combination Package: where non-UN Approved inner containers full of liquids or solids areplaced into a UN Approved container

o Ex: Glass Bottles in a UN Approved Box


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• Overpack: is when properly marked UN Approved containers are placed into another non-UN Approved container. This is typically done for convenience of handling and stowage.

o Ex: 1 UN Approved 5 gallon drum in a box, 4 UN Approved 55 gallon Drums stretch wrapped on a pallet, or many small UN Approved boxes in a large box

• ‘Special Permit’: means a document is issued that allows a person to perform a function that is

not otherwise permitted by the regulations. For example: some SP combination packages do not require hazard labels.

The Packing Group is identified by roman numerals and tells us just how dangerous that product is.

● III – present low danger

● II – present medium danger

● I – present high danger

No Packing Group? It might not be a typo - not all Hazard Classes have a packing group: Explosives, Gases, and Radioactive Material are some examples that do not have a Packing Group.


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If you would like to explore what exactly makes a material Packing Group I rather than Packing Group II or III, many more details about Packing Groups and Classification can be found in Part 173 Subpart D – in the 49 CFR. .

Shipment Size -

● Bulk - BIG shipments (picture examples) ○ Max capacity greater than 450 Liters (119 gallons) for liquids ○ Max capacity greater than 450 Kilograms (882 Lbs) for solids ○ Max capacity greater than 454 Kilograms (1000 Lbs) for gases

● Non-Bulk - If a container has a max capacity smaller than Bulk limits, it is considered non-bulk.

(picture examples)

For the purposes of this training we will only focus on examples that involve fully regulated packing and documentation.

However there are some Exceptions you should be made aware of. These are two examples of commonly used Exceptions that provide relief from some or all requirements of larger shipments:

o Limited Quantity - The volume limits vary based on the material, but details can be found in the ‘Exceptions’ column of the Blue Pages. They have a unique ‘Limited Quantity’ label. Note that the labels for shipping limited quantity by Ground are slightly different than the ones used to ship via Air.

o Excepted Quantity - If you are shipping VERY small amounts of hazardous material - that is: 1oz or less per container, offer relief from UN Approved Packaging and Documentation. Details are provided in 173.4.


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Segregation - Some hazardous material can react dangerously to each other. Table 177.848 describes which items can be stored, loaded or transported together.

● Blank Space - indicates that no restrictions apply ● The letter X indicates that the materials can not be loaded, transported, or stored together in the

same transport vehicle or storage facility during the course of transportation.

● The letter O indicates that they can not be loaded transported or stored together in the same vehicle or facility UNLESS they are separated in a manner tat, in the event of leakage from packages under normal conditions, commingling of hazardous materials would not occur.


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The Shipping Process (at a glance):


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The Shipping Process (detailed description):

Step 1 – Product + Product Label

Review and label details to identify the proper SDS. As the shipper, you are responsible that this information is present and accurate. If it is missing, contact the supplier or create your own version.

Step 2 – SDS Review

Section 1, 2 – confirm the label information is accurate and complete

Section 7, 8 – Handling and Protective Equipment To properly pack the product, there will be some HANDLING involved. This section will provide specific instructions of ‘what to do’ and ‘what not to do’ while working with it. Before touching the product and packing the product put on the appropriate safety gear. This section will provide details about what you need to wear to protect yourself.

Section 14 – Transport Information – This section provides information for ‘IDENTIFYING’ the product in the 49 CFR. Important information includes:

“UN number, Proper Shipping Name, Class, Packing Group”


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Potential variations you might see include:

● Not Otherwise Specified (N.O.S.) Proper Shipping Names – are generic names that are followed by a technical name in parenthesis.

● Multiple Hazard Classes – Primary and Subsidiary Hazard Classes – shown 3(8) ● No Packing Group? Not all substances have a packing group. Explosives, Gases, and

Radioactive Material are some examples of products that don’t have them.

Step 3 – 49 CFR - Part 172.101 – Hazardous Materials Table (Blue Pages)

The Dangerous Goods List is used to select the best packing instruction.

● Proper Shipping Names are listed in alphabetical order ● Follow the row across - confirming the details found in the SDS. ● Select the most appropriate Packing Instruction based on the product’s Packing Group and the

size of the shipment (Non-bulk, Bulk) ● Symbols - found in column 1

+ All hazardous materials should be treated with care, but if you see a plus sign be especially careful. These substances are known to “Pose a risk to humans”

A Subject to the requirements only when offered via Aircraft. If shipped by Ground, it is non-regulated.

D Proper Shipping Name is appropriate for Domestic Transportation. If shipping internationally, check with the manufacturer to ensure the best name is used.

G Technical Name required. This applies to generic ‘N.O.S.’ or ‘not otherwise specified’ shipments. One or more hazardous ingredients should be entered in parenthesis after the proper shipping name. Ex: UN 1993, Flammable Liquid, n.o.s (Hexanols, Isobutanol), 3, II

I Proper Shipping Name is Appropriate for International Transport. If shipping domestically, check with the manufacturer to ensure the best name is used.

W Subject to the requirement only when offered by Vessel


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● Special Provisions in column 7 provide additional requirements or offer relief under certain circumstances. Each Special Provision is listed in 172.102.

o A code consisting only of number (ex: 11) is a multi-modal in application and may apply to bulk and non-bulk packagings

o A__- only Aircraft o B__- only Bulk o IB/IP__- only IBC transport o N__- only Non-bulk o R__- only Rail o T__- only portable Tanks o W__- only Water


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Step 4 – 49 CFR - Part 173.*** – Packing Instructions

The Packing Instructions are used to select appropriate packaging type and size based on quantity limitations.

● Packing Instructions are listed numerically. ● Make sure to read the entire Packing Instruction thoroughly to ensure the correct package is

selected. ● Combination or Single Packaging listings will show what types of inner / outer containers that

can be used. o Packages are described and listed with their Specification Code. The specification code

can also be found on the UN Container itself.


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Step 5 – Pack the product – UN Approved Packaging and Package Closure Instructions

The UN Specification Mark is found on all UN Approved Packages

Package Closure Instructions – step by step instructions that must be followed for the UN Spec mark to be valid. Keys details include: size, type, and number of containers that can be packed; the type of absorbent to use; the type of tape; and exact torque needed. *These must be kept on file*


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Step 6 – Mark and Label the product - 49 CFR - 172.300 / 172.400

This section is very short, but goes into great detail about each mark or label element. so it is good to check it before adding your marks or labels.

All required element are identified and fine details are discussed, including: the Size of the label or font, Location where each label should be placed, and the Orientation of the Labels.

* Labels must not be torn, overlap, cover pre-printed marking, or be folded over an edge.*

Non-Bulk:

A. “Non-Bulk Marks” - 172.301 ● Shipper + full address OR Consignee + full address (both are highly recommended) ● Proper Shipping Name ● UN Number

Size of the UN number ● 30 Liter / 30 Kg or more - at least 12 mm ● 5 - 30 Liter / 5 - 30 Kg - at least 6mm ● 5 Liter / 5 Kg or less - any size appropriate


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Hazard Labels – examples include: ● Size (172.407c): 100 mm on each side / 2 mm solid line, 5 mm from the border

● Placement - 172.406:

Must not overlap, be obscured, or folded over a corner/edge of the container

Must not cover the UN Spec Mark or Orientation Arrows


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Must be located on same surface as PSN - if dimensions are adequate

Should be affixed adjacent to the shipper’s or consignee’s address

Sub Risk required? Must be affixed adjacent to each other on the same surface Multiple Hazard Labels? Must be affixed adjacent to each other

● Overpacks - 173.25 (if applicable)

○ All marks must be reproduced on the outside of the overpack ○ Overpack Label applied - letters are at least 12mm


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Bulk:

Bulk Marks: 172.302 / Labels 172.400 –

● Identification Number ○ Option A) Orange Panel with UN numbers + applicable placards. Place on both

sides, front and back. ○ Option B) Placard with UN numbers. Place on both sides, front and back.

Let’s take a closer look at some of the finer details:

● Size of the numbers – Since the container is large, these also need to be LARGE ○ Over 1000 gallons? 6mm width / 50 mm height – on 4 sides ○ Under 1000 gallons? 4 mm width / 25 mm height – on 2 opposing sides

● Primary Hazard Placards – ○ Only primary placards can contain the UN Number. ○ Sub-risk placards may be used, but are not required


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Step 7 - Placards - 172.500

● Size - 250 mm on each side, 12.5 mm border between edge and solid line ● General – each bulk packaging, freight container, unit load device, transport vehicle or rail car.

Both ends AND both sides.

● DANGEROUS placard – non-bulk packages with two or more categories of hazardous cargo. Used instead of multiple placard types.

○ Limit of 1000 Kg (2205 Lbs) aggregate of each class of material. More than that? Use specific placard.

● Exceptions: A transport vehicle with LESS than 454 Kg (1001 Lbs) and are in Table 2 don’t need placards.


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Step 8 – Documentation – 172.200

Shipping paper designs can vary, just make sure they contain the following required information:


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1) First fill-in the shipper name and address. Next do the same for the Consignee. Keep in mind that it should match the information that is on your box.

2) 24 hour emergency response phone number + company name or contract number

3) Number and Type of Packages

4) Description of Hazardous Materials

5) Indication of Hazmat – Color or ‘X’

6) Hazmat Sequence - must be in order ● UN / ID Number ● Proper Shipping Name (technical name) ● Hazard Class or Division ● Packing Group (in Roman numerals)

7) ‘Overpack Used’ should be place under these details if applicable

8) Authorization (if applicable)

9) Total Quantity / Weight

10) Shipper’s Certification:

“This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.”

“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.”


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11) Shipper’s Signature: �Must be made by:

● a principal, officer, partner, or employee of the shipper OR

● the Shipper’s Agent

Your shipment is in full compliance! To recap, now you have

● A Product that is packed in full compliance - properly packed, marked and labeled. ● Provide at least two copies of the Bill of Lading ● Provide at least one copy of the Safety Data Sheet.


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Don’t Forget! Keep a copy of your back up paperwork for 2 years (172.201).

Documents

Shipping Hazardous Materials by Ground Part 1. General