Pipeline and Hazardous Materials Safety Administration
Hazardous Materials Shipping Descriptions for Agricultural Chemical Products
FAQs
The hazardous materials regulations (HMR; 49 CFR Parts 171-180) provide requirements applicable to the commercial transportation of hazardous materials. Here you’ll find some of the more frequently asked questions by topic area:
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Q. Are shippers and carriers required to keep copies of shipping papers for each hazardous materials shipment?
A. Yes. Persons who provide shipping papers to carriers must retain copies of those shipping papers for a period of two years. Carriers are required to keep the shipping paper for a period of one year after the date that the shipping paper is provided to the carrier. For hazardous waste shipments, the shipping paper must be retained for three years by both the person who provides the shipping paper and the carrier. (See §§ 172.201(e), 174.24(b), 175.33(c)(1), 176.24(b), and 177.817(f)).
Q. In what sequence should the information contained in the basic shipping description for a hazardous material appear on the shipping paper?
A. Effective January 1, 2007, PHMSA adopted a shipping description sequence consisting of identification number first, followed by the proper shipping name, hazard class or division number, and packing group (e.g., UN1133, Adhesives, 3, PG II). This new shipping description sequence is mandatory on shipping documents prepared according to the International Civil Aviation Organization’s Technical Instructions and the International Maritime Dangerous Goods Code. PHMSA adopted this shipping description sequence (see § 172.202(b)) with a 6-year transition period for mandatory compliance. Therefore, for domestic shipments, the shipping description sequence in effect on December 31, 2006 (proper shipping name, hazard class or division number, ID number, and packing group), may be used until January 1, 2013 (see § 171.14(e)).
Q. Is the subsidiary hazard class of a material required to be displayed as part of the basic shipping description on a shipping paper?
A. Yes. The subsidiary hazard class(es) or subsidiary division number(s) must be entered in parentheses immediately following the primary hazard class or division number. For example: UN2744, Cyclobutyl chloroformate, 6.1 (8, 3), PG II. (See § 172.202(a)(3)).
Q. Does a UN 4G fiberboard box require recertification or disposal if over two years have passed since i
ts marked date of manufacture?
A. No, periodic retest requirements apply to the manufacture of a design type, not to empty or filled packagings
which are in use, or are in inventory awaiting use. Once manufactured in conformance with the marked standard (e.g., UN 4G),
the packaging is suitable for use as long as it continues to conform to that standard.
Q. May a package qualified for liquid material be used for a solid hazardous material and vice versa?
A. UN specification packaging tested and marked for the transportation of liquids may be used to ship solid hazardous materials. The maximum gross weight of the solid may not exceed, in kilograms, the rated capacity in liters multiplied by the specific gravity marked on the packaging (1.2 if not marked). (See § 173.24a(b)(3)). A package that has been qualified only for a solid material may not be used for a liquid material.
Q. Is there an exception in the HMR for persons who carry hazardous materials in a motor vehicle to support a job function which is other than transportation?
A. Yes. Section 173.6 provides exceptions for materials that meet the definition of a “material of trade” in § 171.8 and satisfy the conditions and limitations set forth in § 173.6. An informational brochure on the material of trade exception is available at the following Web site:
http://hazmat.dot.gov/pubs/hm200/mots05.pdf
Q. Is there an exception for very small quantities of hazardous materials?
A. Yes. Section 173.4 provides exceptions for small quantities of hazardous materials. Materials which satisfy the quantity limitations of this section, and are prepared and offered for transportation in accordance with this section, are not subject to any other requirements of the HMR. Packages used to transport small quantities must be capable of passing a drop test and a compressive load test, as specified in § 173.4.
Q. Two different hazardous materials (i.e., different shipping names and identification numbers) in non-bulk packages are loaded onto a motor vehicle at one facility in quantities exceeding an aggregate gross weight of more than 4,000 kg (8,820 lbs.) for each material. Must the motor vehicle display the identification number for each material?
A. No. The identification number marking display applies only when 4000 kg (8,820 pounds) or more of a single hazardous material (i.e., one shipping name and identification number) in non-bulk packagings are loaded at one loading facility. See § 172.301(a)(3) and the following examples:
- ID# Required
- > 4000 kg (8,820 pounds) of hazmat at one loading facility; and consists of only one hazardous material with the same proper shipping name and identification number.
- ID# NOT Required
- < 4000 kg (8,820 pounds); or not all the same hazardous material on vehicle.
Q. Is an identification number marking required on a transport vehicle or freight container containing non-bulk packages of materials poisonous by inhalation?
A. When a transport vehicle or freight container is loaded at one loading facility with more than 1,000 kg (2,205 pounds) of non-bulk packagings containing a single hazardous material (i.e., marked with the same proper shipping name and identification number) that is poisonous by inhalation in Hazard Zones A or B, the identification number for that material must be displayed on the transport vehicle or freight container, as prescribed in § 172.313(c).
When a transport vehicle or freight container is loaded at one loading facility with more than 1,000 kg (2,205 pounds) of non-bulk packagings containing a single hazardous material (i.e., marked with the same proper shipping name and identification number) that is poisonous by inhalation in Hazard Zones A or B, the identification number for that material must be displayed on the transport vehicle or freight container, as prescribed in § 172.313(c).
Q. What are the requirements for marking a transport vehicle or freight container containing lading which has been fumigated?
A. A transport vehicle or freight container in which the lading has been fumigated with any material, or is undergoing fumigation, is considered a package containing a hazardous material, unless it has been sufficiently aerated so that it does not pose an unreasonable risk to health and safety. Fumigated transport vehicles or freight containers may not be offered into transportation or transported unless they prominently display a fumigant marking (see §§ 172.302(g) and 173.9) that can be seen by any person attempting to enter the interior of the transport vehicle or freight container.
Q. May the International Maritime Dangerous Goods Code (IMDG) label for limited quantity shipments, with the UN identification number for the material in a white square-on-point diamond, be used to meet the marking requirements for limited quantity shipments under § 172.315 of the HMR?
A. Yes. As specified in § 172.315, except for transportation by aircraft, marking the package with the identification number inside a white square-on-point configuration identifies the material as a limited quantity and fulfills the requirements of § 172.301(a)(1). If a shipper uses this method to identify packages containing limited quantities, the shipper is not required to mark the proper shipping name or technical name on the outer package. The letters “RQ” must be marked in association with the limited quantity marking when the package contains a reportable quantity of a hazardous substance. The name(s) of the hazardous substance must be marked, in parentheses, in association with the identification number on the package. If the material contains two or more hazardous substances, the names of at least two hazardous substances, including the two with the lowest reportable quantities (RQs), must be marked on the package. For a hazardous waste, the waste code (e.g., D001), if appropriate, may be used to identify the hazardous substance.
Q. What markings are required on overpacks?
A. Section 173.25(a)(4) requires an overpack to be marked with the word “OVERPACK”, unless the specification markings on the inside packages are visible or the packages inside the overpack are not required to be specification packages. The overpack must also be marked with the proper shipping name, identification number, and orientation arrows, when applicable, and be labeled as required for each hazardous material contained therein, unless the markings and labels for each hazardous material in the overpack are visible.
Q. Where must the markings describing a hazardous material appear on the package?
A. As specified in § 172.304, markings must be durable, in English, printed on or affixed to the surface of a package using a label, tag, or sign. The markings must be displayed on a sharply contrasting background and must be unobscured by labels or attachments and must be located away from any other marking (such as advertising) that could substantially reduce their effectiveness.
Q. Can markings used to describe a hazardous material be handwritten?
A. Yes, provided the handwritten markings satisfy the applicable HMR requirements for size, location, durability and display. See § 172.304.
Q. What are the size requirements for markings?
A. For non-bulk packagings, markings may vary in size provided they are clearly visible. Except as otherwise provided by the HMR, markings on bulk packagings must have a width of at least 6.0 mm (0.24 inch) and a height of at least 100 mm (3.9 inches) for rail cars; have a width of at least 4.0 mm (0.16 inch) and a height of at least 25 mm (one inch) for portable tanks with capacities of less than 3,785 L (1,000 gallons) and intermediate bulk packagings (IBCs); and, have a width of at least 6.0 mm (0.24 inch) and a height of at least 50 mm (2.0 inches) for cargo tanks and other bulk packagings. See § 172.302(b).
For UN specification non-bulk packagings and IBCs, the specification markings must be at least 12.0 mm (0.47 inches) in height except that for packagings of less than or equal to 30 L (7.9 gallons) capacity for liquids or 30 kg (66 pounds) capacity for solids the height must be at least 6.0 mm (0.2 inches). For packagings having a capacity of 5 L (1 gallon) or 5 kg (11 pounds) or less, letters and numerals must be of an appropriate size. See §§ 178.3 and 178.703.
For DOT specification cylinders, the specification marking must be at least 0.25 inch, or as space permits (see § 178.35(f)).
Additional size requirements for specification markings on cargo tanks, portable tanks, tank cars and UN specification cylinders are as follows:
- Cargo tanks: see Part 178, Subpart J
- Portable tanks: see Part 178, Subpart H
- Tank cars: see Part 179.
- UN cylinders: see § 178.71(o).
Q. Where must the labels be located on a packaging in relation to other labels and markings?
A. Labels must be located on the same surface of the package and near the proper shipping name marking, if the package dimensions are adequate. A label may be printed on or placed on a securely affixed tag, or may be affixed by other suitable means to a package that contains no radioactive material and has dimensions less than those of the required label; a cylinder; or, a package with an irregular surface upon which a label cannot be satisfactorily affixed. Labels representing subsidiary hazards must be displayed within 150 mm (6 inches) of the other required labels (§172.406(c)).
Q. Must the labels be in a square-on-point orientation?
A. While it is the intent of the HMR that a label be oriented square-on-point on a package when possible, the requirements in § 172.406 do not prohibit the placement of hazard warning labels in an orientation where the square-on-point is located with its flat sides parallel to the edge of the package.
Q. What, if any, color modifications are authorized on labels?
A. The color of a hazard warning label must fall within the color tolerances on the appropriate color chart provided in Appendix A to Part 172 (See § 172.407(d)(4)). Labels conforming to PANTONE® color standards are also acceptable in accordance with § 172.407(d)(5).
Q. May international labels be used domestically?
A. Section 172.401(c) permits labeling in conformance with the International Civil Aviation Organization's Technical Instructions, IMDG Code, or Canadian Transport of Dangerous Goods Regulations. Section 172.407(f ) permits labeling in conformance with the UN Recommendations on the Transport of Dangerous Goods.
Q. Is there an exception from the placarding requirements for small loads of hazardous materials?
A. Yes. Section 172.504(c) provides an exception from the placarding requirements for hazardous materials listed in Table 2 of § 172.504(e), provided the hazardous materials are contained in non-bulk packages and the aggregate gross weight of Table 2 materials contained in a single transport vehicle or freight container does not exceed 454 kg (1,001 pounds).
Q. May international placards be used domestically?
A. International placards are permitted domestically if the shipments are prepared in accordance with recognized international standards (i.e., International Civil Aviation Organization's Technical Instructions, IMDG Code, or Canadian Transport of Dangerous Goods Regulations). See § 171.22.
Q. When may a DANGEROUS placard be used?
A.
A freight container, unit load device, transport vehicle, or rail car containing non-bulk packages with two or more categories of hazardous materials that require different placards specified in Table 2 of § 172.504(e) may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in Table 2. However, when 1,000 kg (2,205 pounds) aggregate gross weight or more of one category of material is loaded at one loading facility on a freight container, unit load device, transport vehicle, or rail car, the placard specified in Table 2 of paragraph (e) of this section for that category must be applied.
Q. Are Class 9 placards required domestically?
A.
Class 9 (Miscellaneous) materials, although listed in Table 2, are not required to be placarded for domestic transportation (see §172.504(f)(9)). However, a bulk packaging containing a Class 9 (Miscellaneous) material must be marked with the appropriate ID number, which can be displayed on a Class 9 placard, an orange panel, or a white square-on-point display.
Q. How long can Organic Peroxide Placards and Labels meeting the specifications in effect before December 31, 2006, continue to be used?
A.
The new Organic Peroxide label and placard designs feature a red background in the top half and a yellow background in the lower half. In addition, the text, division number, and inner border of the placard must be black; however, the symbol may be either black or white. The new label and placard design may be used now. You may continue to use the old style label design until January 1, 2011. You may continue to use the old style placard until January 1, 2014, by highway, and until January 1, 2011, by rail, vessel, or aircraft.
Old Style Organic Peroxide Label & Placard
 
New Style Organic Peroxide Label & Placard
 
Q. May a hazmat employer/employee train and test himself or herself (e.g., owner-operator)?
A. Yes, self-training is acceptable provided that all training requirements of § 172.704 are met, including maintaining records of current training.
Q. Who certifies that an instructor is qualified to train, test, and certify in accordance with § 172.704?
A. There is no requirement for certification of trainers required under Subpart H of Part 172. The employer must determine whether a trainer is qualified to provide the required training.
Q. Does the trainer who teaches and tests the hazmat employee certify that the hazmat employee is trained/tested?
A. The hazmat employer is responsible for certifying that the employee has been trained and tested. However, a hazmat employer may designate an outside source to train, test, and certify on its behalf. See § 172.704.
Q. Must the test be in a written format or may a skill demonstration be used?
A. Any test that ensures that the employee can perform the assigned duties in compliance with the HMR is acceptable. Training and testing may be accomplished in a variety of ways: performance, written, verbal, or a combination of these. See § 172.702(d).
Q. Must the employee "pass" a test?
A. The requirements do not state that the employee must "pass" a test; however, an employee may only be certified in areas in which he/she can successfully perform his or her hazmat duties. See § 172.702(b).
Q. Does IMDG Code, ICAO Technical Instructions, OSHA or EPA training fulfill the HMR requirements?
A. This training often includes general awareness, function specific, and safety subject matter; however, the hazmat employer must ensure that the training and testing requirements of the HMR are met. Portions of these categories not covered and any other training requirements (e.g., security awareness training) will require additional training. See § 172.704(b).
Q. Does a Commercial Driver's License (CDL) with a hazmat endorsement satisfy the training requirements under the HMR?
A. Compliance with requirements for a CDL with a hazardous materials endorsement provides a driver with the general knowledge and skills necessary to safely operate a commercial motor vehicle with hazardous materials cargo and may satisfy some of the training requirements of the HMR (see §§ 172.704 and § 177.816). Additional training may be required based on the job function and material-specific requirements related to the handling of hazardous materials (i.e., operation of emergency valves, cargo tank specification requirements, security awareness, etc.). It remains the responsibility of a hazmat employer to determine the extent to which the CDL hazmat endorsement satisfies the training requirements of the HMR.
Q. Do the HMR training regulations apply to foreign flag vessels carrying hazardous materials?
A. Yes, the regulations apply to each domestic and foreign vessel when in navigable waters of the United States.
Q. Do the HMR training regulations apply to a hazmat employer and employees who operate a bulk vessel transporting hazardous materials?
A. No. Except for transportation in bulk packagings (See § 171.8), the bulk carriage of hazardous materials by water is governed by 46 CFR Chapter I. See § 176.5(d).
Q. What are the registration requirements?
A. The registration and fee requirements apply to any person who offers for transportation, or transports, in foreign, interstate or intrastate commerce:
- A highway route-controlled quantity of a Class 7 (radioactive) material;
- More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material in a motor vehicle, rail car or freight container;
- More than 1 L (1.06 quarts) per package of a material extremely toxic by inhalation ( i.e., “material poisonous by inhalation,” that meets the criteria for “hazard zone A,);
- A shipment of a quantity of hazardous materials in a bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids;
- A shipment in other than a bulk packaging of 2,268 kg (5,000 pounds) gross weight or more of one class of hazardous materials for which placarding of a vehicle, rail car, or freight container is required for that class, under the provisions of subpart F of part 172; or,
- A quantity of hazardous material that requires placarding under provisions of subpart F of part 172 of this chapter.
See § 107.601. Exceptions from the registration requirements are in §§ 107.601(b) and 107.606.
Q. Who is responsible for registering, the shipper or carrier?
A. Generally, both. In accordance with § 107.601, a person who offers or transports hazardous materials in the amounts listed must register. The term “person who offers” is defined in 171.8. Hazmat registration required by PHMSA is different from the registration for new US DOT numbers and operating authority required by the Federal Motor Carrier Safety Administration (FMCSA). Additional information on registration for a new US DOT number and operating authority for highway carriers is available at FMCSA’s registration and licensing Web site.
Q. Do I need to contact the DOT if I no longer need to register?
A. No, you do not need to de-register or otherwise contact the DOT if you no longer are subject the registration requirements. You may simply let the registration lapse.
Additional information regarding the registration program, including the registration form and brochure, is available at the following Web site:
http://hazmat.dot.gov/regs/register/register.htm
Q. Who is required to develop and implement a security plan?
You must develop and implement a security plan if you offer for transportation or transport the following types and quantities of hazardous materials:
- A highway route-controlled quantity of a Class 7 (radioactive) material;
- More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material in a motor vehicle, rail car or freight container;
- More than 1 L (1.06 quarts) per package of a material extremely toxic by inhalation ( i.e., “material poisonous by inhalation,” that meets the criteria for “hazard zone A,);
- A shipment of a quantity of hazardous materials in a bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids;
- A shipment in other than a bulk packaging of 2,268 kg (5,000 pounds) gross weight or more of one class of hazardous materials for which placarding of a vehicle, rail car, or freight container is required for that class, under the provisions of subpart F of part 172;
- A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR Part 73; or
- A quantity of hazardous material that requires placarding under provisions of subpart F of part 172 of the HMR.
An exception for farmers, who generate less than $500,000 annually in gross receipts from the sale of agricultural commodities or products, is given in 172.800(c). Additional guidance on hazardous materials security, including a comprehensive list of FAQs on security plan requirements, is available at the following Web site:
http://hazmat.dot.gov/riskmgmt/hmt/hmt_security.htm
Q. Are domestic UN pressure receptacle cylinder manufacturing facilities required to have on-site inspections prior to building UN pressure receptacles?
A. Yes. Each manufacturer of a UN pressure receptacle is subject to an on-site production assessment as specified in § 178.70(f)(1). This assessment is required of both foreign and domestic manufacturers of UN pressure receptacles.
Q. Who is authorized to conduct cylinder requalification on DOT specification and special permit cylinders?
A. No person may represent that a repair or requalification of a cylinder has been performed in accordance with the requirements unless that person has been issued a requalifier identification number (RIN) under the procedural requirements prescribed in § 107.805. Lists of current persons authorized to requalify cylinders, by RIN and state, are available at:
http://hazmat.dot.gov/sp_app/approvals/hydro/hydro_retesters.htm
Q. Are there federal requirements for transporting batteries and battery-powered equipment in checked or carry-on baggage on passenger carrying aircraft?
A. There are Federal regulations with very specific provisions regarding transportation of batteries and battery-powered equipment in checked and carry-on baggage on passenger aircraft. On March 26, 2007, PHMSA issued a safety advisory notice about the importance of properly packing and handling batteries and battery-powered devices when they are carried aboard aircraft. Guidelines on the safe carriage of batteries and other commonly carried consumer items (e.g., lighters, matches, aerosols, and ammunition) are available for travelers at safetravel.dot.gov.
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