Q.01

What needs to be on hazmat shipping papers?

Under US DOT rules (49 CFR Part 172, Subpart C), a hazmat shipping paper has to show five things: the basic description in a fixed order, the total quantity and the number and type of packages, any extra entries that apply to the material, the shipper's certification, and an emergency response telephone number backed by emergency response information (Subpart G). This summary comes from the official eCFR text of 49 CFR Part 172. Our datasets hold only the §172.101 Hazardous Materials Table, which is where the description entries come from, not the shipping-paper rules themselves.

1. Basic description (§172.202) These four items must appear in this order with nothing else between them:

  1. Identification number (§172.101 Table, Column 4)
  2. Proper shipping name (Column 2)
  3. Hazard class or division (Column 3), with any subsidiary hazards in parentheses
  4. Packing group in Roman numerals (Column 5)

The rule's own example is "UN2744, Cyclobutyl chloroformate, 6.1, (8, 3), PG II".

You also need:

  • Total quantity, by mass or volume with the unit, e.g. "200 kg" or "50 L". It can go before or after the description, or both. For air shipments, net mass per package is used instead.
  • Number and type of packages, e.g. "12 drums".
  • Technical names, where required: in parentheses between the shipping name and the hazard class, or after the basic description. Example: "UN 1993, Flammable liquids, n.o.s. (contains Xylene and Benzene), 3, II".
  • Never put a hazard class or ID number on a paper for a material that is not regulated as hazardous (§172.202(e)).

2. Additional entries when they apply (§172.203)

  • Special permit: "DOT-SP" followed by the permit number
  • "Limited Quantity" or "Ltd Qty"
  • Hazardous substances: "RQ", plus the substance name in parentheses if it is not already in the shipping name
  • Radioactive material: the radionuclide names, physical/chemical form, activity, label category and transport index
  • Marine pollutants: "Marine Pollutant" and the names of the components that make it one
  • Materials toxic by inhalation: "Poison-Inhalation Hazard" or "Toxic-Inhalation Hazard", with the Zone
  • Elevated-temperature materials: "HOT" before the proper shipping name
  • Temperature-controlled organic materials: "TEMPERATURE CONTROLLED", with the control and emergency temperatures

3. Format and retention (§172.201)

  • Hazmat entries must stand out from non-hazardous items: listed first, printed in a clearly contrasting colour, or marked "X" in an "HM" column.
  • Entries must be legible and in English, with no codes or abbreviations unless the rules allow them.
  • Keep copies for 2 years, or 3 years for hazardous waste, and make them available to authorities on request.

4. Shipper's certification (§172.204) The standard wording is: "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."

  • A wording aligned with international rules is also accepted.
  • For air, add: "I declare that all of the applicable air transport requirements have been met."
  • It must be signed by the principal, an officer, a partner or an employee. The signature can be manual, typed or mechanical.

5. Emergency response (§§172.600–172.604)

  • Telephone number:

    • It must be monitored at all times the material is in transport, including storage incidental to transport.
    • It must reach someone who knows the material, or who has immediate access to someone who does. Callback services are not allowed.
    • Put it right after the description, or display it prominently and clearly identified as an emergency contact.

  • Emergency response information must cover:

    • the basic description and technical name
    • immediate health hazards
    • fire or explosion risks
    • immediate precautions after an accident
    • how to handle fires
    • how to handle spills or leaks when there is no fire
    • first aid

    It must be in English and usable away from the package. It can be on the shipping paper itself, on a safety data sheet, or in a separate cross-referenced document.

Exceptions and special cases:

  • Shipping papers are not needed for limited-quantity packages (except by air or vessel), Category B infectious substances, or materials marked "A" or "W" in the Table when not moving by air or water respectively (§172.200).
  • The emergency phone number rule does not apply to limited or excepted quantities, or to certain listed materials such as dry ice and consumer commodities (§172.604).
  • Hazardous waste also needs the EPA Uniform Hazardous Waste Manifest, Form 8700-22, signed by the generator and the first carrier (§172.205).

If a shipment moves by sea or air, the IMDG Code or the ICAO/IATA rules add their own documentation requirements; I haven't covered those here.

Approach: I read 49 CFR Part 172, Subparts C and G, through the official eCFR service and checked the basic-description order against PHMSA's guidance. Our datasets cover the §172.101 Hazardous Materials Table but not the shipping-paper rules, and PHMSA's shipping-papers guidance PDF could not be opened.

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Q.02

How do I pick the packing group?

Start with the Hazardous Materials Table (§172.101). If Column 5 shows only one packing group for your proper shipping name, that is the packing group you use. If it shows more than one, you pick the right one by testing your material against the criteria for its hazard class in 49 CFR Part 173, Subpart D. Packing Group I means great danger, II medium danger and III minor danger (§171.8).

Step 1: Read Column 5 of the Table

  • Column 5 lists the packing group or groups for each proper shipping name and hazard class. Where more than one is listed, §172.101 says to use "the criteria for assignment of packing groups specified in subpart D of part 173."
  • One packing group shown: for example, Acetone (UN1090, Class 3) is listed only as PG II [1].
  • Several shown: n.o.s. and generic entries usually work this way. "Flammable liquids, n.o.s." (UN1993) has separate PG I, II and III lines [2][3][4], so your test data decides which line applies.
  • No packing group at all: Class 2, Class 7 and Division 6.2 have none. Articles in classes other than Class 1 have none either.

Step 2: Apply the criteria for the hazard class

ClassSectionHow the packing group is set
3 Flammable liquids§173.121PG I: initial boiling point ≤35 °C. PG II: flash point <23 °C and boiling point >35 °C. PG III: flash point ≥23 °C and ≤60 °C, boiling point >35 °C.
4.1, 4.2, 4.3§173.125By test results. 4.1: burning rate (e.g. PG II if burning time is under 45 s and the flame passes the wetted zone). 4.2: pyrophoric materials are PG I; self-heating materials go by temperature and sample-size tests. 4.3: flammable gas given off on contact with water, PG I at ≥10 L/kg/min, PG II at ≥20 L/kg/hr, PG III at >1 L/kg/hr.
5.1 Oxidizers§173.127Burning time or rate compared with reference mixtures.
6.1 Toxic§173.133PG I: oral LD50 ≤5 mg/kg, dermal ≤50 mg/kg, dust/mist LC50 ≤0.2 mg/L. PG II: above those, up to oral ≤50, dermal ≤200, LC50 ≤2.0. PG III: up to oral ≤300, dermal ≤1000, LC50 ≤4.0. Vapours are graded on both LC50 and saturated vapour concentration (PG I splits into Zones A and B).
8 Corrosive§173.137PG I: irreversible skin damage after an exposure of 3 minutes or less (observed for up to 60 minutes). PG II: exposure of more than 3 and up to 60 minutes (observed for up to 14 days). PG III: exposure of more than 60 minutes and up to 4 hours, or no skin damage but corrosion of both steel and aluminium faster than 6.25 mm a year at 55 °C.

Subpart D has no packing-group section for Division 5.2 or Class 9.

Exceptions that change the result

  • Viscous flammable liquids (§173.121): a material that would be PG II can drop to PG III if it meets all the conditions:
    • less than 3% clear solvent separates in the solvent separation test
    • no Division 6.1 or Class 8 component
    • package capacity limits are met (450 L generally; 30 L on passenger aircraft, 100 L on cargo aircraft)
    • the viscosity and flash point fall within the combinations in the section's table
  • More than one hazard (§173.2a): for materials meeting more than one of Class 3, Class 8 and Divisions 4.1, 4.2, 4.3, 5.1 and 6.1, the Precedence of Hazard Table decides the primary class. The strictest packing group across all the hazards then applies. The rule's own example: a material that is Class 3 PG II and Division 6.1 PG I (oral toxicity) ships as Class 3 PG I.

Write the packing group you end up with on the shipping paper in Roman numerals, as the last item of the basic description.

Approach: I checked example entries in the §172.101 Hazardous Materials Table in our datasets. The assignment criteria in 49 CFR Parts 171 and 173 are not in our datasets, so I read them in the official eCFR text.

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Q.03

Where do shipping papers have to be kept in the truck?

The rule is 49 CFR 177.817(e), and where the papers go depends on where the driver is. When the driver is at the controls, the paper must be within the driver's immediate reach while restrained by the lap belt. It must also be either readily visible to someone entering the driver's compartment or in a holder mounted on the inside of the driver's door. When the driver is away from the vehicle, the paper must be in the driver's-door holder or on the driver's seat.

What §177.817(e) requires

  • General duty: the driver and the carrier must keep the shipping paper "readily available to, and recognizable by, authorities in the event of accident or inspection."
  • Make it easy to find: if the hazmat shipping paper is carried with other papers, it must stand out from them. It has to be either "distinctively tabbing it or by having it appear first" in the stack (§177.817(e)(1)).
  • Driver at the controls: the paper must be "within his immediate reach while he is restrained by the lap belt." It must also be either:
    • readily visible to a person entering the driver's compartment, or
    • in a holder mounted to the inside of the door on the driver's side.
  • Driver not at the vehicle: the paper must be either:
    • in the holder mounted to the inside of the driver's-side door, or
    • on the driver's seat.

Related points in the same section

  • A carrier may not accept or transport hazmat by highway without a shipping paper prepared under Part 172 (§177.817(a)). This does not apply to materials excepted from shipping papers under §172.200 (§177.817(d)).
  • How long the carrier keeps copies (§177.817(f)):
    • 3 years for hazardous waste
    • 1 year for other hazardous materials
    • Copies must be made available to government officials on request.

Approach: I checked the RegAffairs datasets first. The only DOT hazmat material they hold is the §172.101 Hazardous Materials Table, not the highway carrier rules in 49 CFR Part 177, so I read §177.817 in the official eCFR text.

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Q.04