During the fog of this first day of class, we delve into the DOT Hazardous Materials Regulations. While some may question why we need to cover such regulations, the need to do so is undeniable due to the fact that hazardous materials technicians may encounter hazmat incidents on the highway, railroad, or water in which the DOT Hazardous Materials Regulations apply. Technicians may also interface with employees at facilities that ship hazardous materials who by virtue of their job duties are required to receive DOT Hazardous Materials Transportation Training.
The DOT Hazardous Materials Transportation Regulations (abbreviated as the HMR) exist within Title 49 of the Code of Federal Regulations, Parts 100-185. Under the HMR, hazardous materials employees that perform certain functions relating to hazardous materials transportation are required to complete training in the areas of general awareness/familiarization, function-specific training, safety training, security awareness training and in-depth security training — the latter is required if the facility is required to have a security plan. The training is required within 90 days of employment or a change in job function and recurrent training is required every three years. For in-depth security training it is required every three years or within 90 days of the implementation of a revised safety plan.
One of the areas in which we encounter the HMR as hazmat technicians is in the case of shipping papers. Whether we are looking at a bill of lading in highway transportation or a consist in rail transportation, hazardous materials are required to be listed by their basic description. This information is found in the HMR within the Hazardous Materials Table (HMT), in which hazardous materials are listed in alphabetical order of their proper shipping name. Information in the HMT is listed in specifically designated columns. Column one is not part of the basic description, but rather may contain any of six symbols utilized to further describe the entry. For example, a “+” fixes the proper shipping name, hazard class and packing group for the entry without regard to the entry meeting hazard class or packing group definitions. An “A” indicates materials that are subject to the regulations when transported by air, and a “D” designates proper shipping names which are only appropriate for domestic transportation.
The basic description of hazardous materials consists of the information contained in columns two through five of the HMT, but not in the numerical order of columns. The first component of a basic description is found in column four, which is the UN/NA ID number of the material. As we know the UN/NA ID number is a four-digit number that identifies a hazardous material or family of materials. The second component of the basic description is found in column two of the HMT and is the proper shipping name of the material. The proper shipping name is indicated in bold type, with text in italics denoting additional descriptors that are not part of the shipping name but may be used. The third component of the basic description is found in column three and is the hazard class or division of the material. This element is a numerical entry that describes which of the nine DOT Hazard Classes or divisions thereof the material is categorized within. The final component of the basic description is found in column five, which is the packing group of the material. The packing group represents the relative hazard of the material and is represented by Roman numerals and may be preceded by “PG”. PG I materials present a great danger; PG II materials present a medium danger and PG III materials present a minor danger. An example of a basic description would therefore be as follows:
UN 1090, Acetone, 3, PG II
The order of the basic description elements was changed to the present-day order on January 1, 2013. In addition to the basic description elements listed above, the complete shipping description required on a shipping paper would include the basic description plus the total quantity of the material — except when transported by aircraft — or the total net mass per package for air transportation; and the number and type of packages.
The HMT also contains several additional columns of information that pertain to additional shipping information. Column six corresponds to the labels that are used to identify individual packages. The primary required label and any required subsidiary labels will be noted in column six. Column seven lists codes that are used to denote special provisions for transportation that are covered in 49 CFR 172.102. Any letters preceding the numerical code specify the mode of transportation the special provision refers to (e.g. “A” for air, “B” for bulk transportation, etc.). Column eight refers to packaging authorizations and is divided into three sub-columns (8A, 8B, and 8C). Column 8A refers to any packaging exceptions, and the number indicated specifies the exact location in 49 CFR 173 at which the exception is found. For instance, “153” indicates that the exception is located at 49 CFR 173.153. f no exceptions exist, the word “None” will be displayed in Column 8A. Exceptions are grouped by DOT Hazard Class, and additional exceptions exist for limited quantities, other regulated materials (hazardous materials shipped in limited quantities presenting a limited hazard, such as consumer commodities), and reverse logistics shipments.
Columns 8B and 8C refer to non-bulk and bulk packaging requirements. Non-bulk packages are those with a capacity of 119 gallons or less for liquids, a net mass of 882 pounds or less and a maximum capacity of 119 gallons or less for solids; and a water capacity of 1000 pounds or less for gases. Bulk packages are those above the capacity/mass thresholds that are stipulated for non-bulk packages. As with column 8A, the numbers specified in columns 8B and 8C refer to the location in 49 CFR 173 at which the packaging requirements are found.
The next column in the table- — column nine — refers to the quantity limitations per individual package for transportation by passenger aircraft or rail (column 9A); and cargo aircraft (column 9B). The limitations are specified in kilograms or liters. The designation “Forbidden” indicates that the material may not be offered for transportation or transported by the mode of transport indicated. Further information on Columns 9A and 9B can be found in 49 CFR 173.27 and 175.75. The final column in the HMT is column 10, which refers to vessel stowage requirements in transportation by water. Column 10A indicates the location or locations at which the material may be stowed. The codes utilized in column 10A are defined in 49 CFR 172.101(k)(1 - 10). Column 10B displays codes that indicate other provisions for transportation by water. The definitions of those codes are found in 49 CFR 176.84.
As can be witnessed in our discussion above, the Hazardous Materials Table is designed for use by hazardous materials employees that perform certain functions related to hazardous materials transportation. As hazardous materials technicians, however, we should also be familiar with the contents and use of the HMT. Personally, I view HMT-related training in the same light as the requirement of the prerequisite chemistry of hazardous materials class to be completed prior to certification as a hazmat technician in the State of North Carolina. Many personnel ask why should such training is needed, and I always reply that our credibility on the hazmat scene is difficult to obtain but can be easily lost. By completing the training discussed above, we can speak the same language at hazmat scenes as the personnel we interface with. This allows our credibility to remain intact and the knowledge gained assists immeasurably with the successful mitigation of hazardous materials incidents.
As always, stay safe out there and be sure to visit the North Carolina Association of Hazardous Materials Responders website at www.nchazmat.com
Glenn Clapp is a past president of the North Carolina Association of Hazardous Materials Responders and has over 22 years of fire service and emergency management experience. He is currently an Improvement Specialist with the Industry Expansion Solutions Division of North Carolina State University and is a volunteer firefighter with the Fairview Fire Department. He is also a Technician-Level Hazmat Instructor, an Executive Fire Officer, a Certified Hazardous Materials Manager and a Certified Fire Protection Specialist.