The Hazardous Materials Regulations of the USDOT/PHMSA contain specific requirements for the description of a hazardous material on a shipping paper, known as the Proper shipping Description. One component of the Proper Shipping Description is the Basic Description; the purpose of which is to – just like the name implies – provide a basic description of the potential hazards presented by a material in transportation. This article will explain how a change to the order of the Basic Description (effective January 1st, 2013) affects other responsibilities of a HazMat shipper and a possible source of confusion when using the Uniform Hazardous Waste Manifest for the transportation of a hazardous waste. Show As of January 1, 2013 the order to the four elements of the Basic Description changed as indicated below [49 CFR 172.202(b)]: Optional for domestic transportation of HazMat until December 31, 2012:The Basic Description Proper Shipping Name Hazard Class/Division Identification Number Packing Group Waste Flammable Liquid, n.o.s. 3 UN1993 PG II Or…The Basic Description Identification Number Proper Shipping Name Hazard Class Packing Group UN 1993 Waste Flammable Liquid, n.o.s. 3 PG II Mandatory for all HazMat transportation as of January 1, 2013:The Basic Description Identification Number Proper Shipping Name Hazard Class Packing Group UN 1993 Waste Flammable Liquid, n.o.s. 3 PG II Since the word “Waste” doesn’t appear in the Hazardous Materials Table of 49 CFR 172.101 (with a few exceptions) you may wonder how it wound up as part of the Proper Shipping Name. Read this earlier article of mine for clarification: Waste and the Proper Shipping Name for Shipments of Hazardous Waste. This revision to the HMR was undertaken for two reasons: (1) To harmonize the USDOT/PHMSA’s domestic regulations with those of international organizations and foreign states, and (2) To ensure critical information (the Identification Number) is clearly visible to first responders in an emergency. Unfortunately this change to the sequence of the Basic Description has created confusion in two related areas of HazMat communication:
First, 49 CFR 172.301 specifies the marking requirements for non-bulk packagings of hazardous materials, which must include the Proper Shipping Name and Identification Number of the HazMat as required by the Hazardous Materials Table @ 49 CFR 172.101. §172.301 does not, however, mandate a sequence to the display of the markings, nor does it reference §172.202(b), which established the sequence of the Basic Description for shipping papers. So, the change to the order of the Basic Description – mandatory on all HazMat shipping papers – does not affect the appearance of the Proper Shipping Name and Identification Number as a marking on a non-bulk packaging of a hazardous material; which may continue to appear as: “Waste Flammable Liquid, n.o.s. UN1993” The second area of confusion has to do with the sequence of the Basic Description on the Uniform Hazardous Waste Manifest. The manifest is a shipping paper required by both the USEPA (and authorized state) and the USDOT/PHMSA for the transportation of a hazardous waste. This dual responsibility has led to what may appear to be contradictory information from these two Agencies regarding the sequence to the Basic Description on the Manifest. This is a confusion I will try to dispel. Three points must be made clear:
As made clear earlier, the regulations of the USDOT/PHMSA mandate the order of the Basic Description as this [§172.202(b)]:
However, the guidance for Item 9b of the Uniform Hazardous Waste Manifest reads:
Sowing additional seeds of confusion are the USEPA Instructions for completion of the Manifest (Appendix to Part 262), where Item 9 reads:
And the instructions for Item 9b:
So which is it? The answer lies in the clarity of the USDOT/PHMSA regulations which mandate a particular sequence to the Basic Description and the ambiguity of the guidance and instructions of the USEPA which imply a particular sequence (now no longer acceptable) but do not mandate a particular sequence in its regulations. A careful review of the USEPA instructions reveals that at no place does it mandate an order to the Basic Description, though one is implied. The answer, confirmed by a call to the USDOT/PHMSA HazMat Info Line, is that you must follow the regulations of the USDOT/PHMSA for the transportation of all hazardous materials, which includes hazardous waste. This means using the sequence to the Basic Description prescribed by the USDOT/PHMSA in the HMR [§172.202(b)]. The transportation of a hazardous waste adds another level of complexity to a routine shipment of a hazardous material due to the presence of the USEPA and its regulations. Make certain that as a shipper of a hazardous material and a generator of a hazardous waste you are in compliance with both the Hazardous Material Regulations of the USDOT/PHMSA and the hazardous waste (RCRA) regulations of the USEPA. What are the 4 types of hazardous materials?Class 1: Explosives. Class 2: Gases. Class 3: Flammable Liquids. Class 4: Flammable Solids or Substances.
What are the parts of the basic shipping description?Basic description means the information comprising the identification number, Proper Shipping Name, primary and subsidiary hazard class(es) or division(s), and packing group, when applicable, as prescribed in §172.202(a), (b), (c), and (d) of this subchapter.
What are the 4 flammable hazard classes?Flammable gases Flammable aerosols Flammable liquids Flammable solids These four classes cover products that have the ability to ignite (catch fire) easily.
What is a hazard class 4?Hazard Class 4 – Flammable Solids
These are the three divisions of flammable solids along with a common example for each: Flammable solid (4.1) (e.g., match sticks), Spontaneously combustible material (4.2) (e.g., oily rags) Dangerous when wet (4.3) (e.g., magnesium fire starter)
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