Simplifying the CFR Shipping Rules
Even Einstein would have trouble understanding hazardous materials or dangerous goods (DG) regulations, agree 56 percent of respondents to a recent Labelmaster survey. And simply keeping pace with the changes in regulations is an inherent challenge, say 59 percent of respondents.
With their daunting appearance, and massive word count, regulations can seem intimidating. They aren’t. Nikki Burgess, DGSA, CDGP, staff regulatory specialist with Labelmaster, simplifies the 49 Code of Federal Regulations (CFR) governing hazardous materials shipments.
1. Apply the correct label. A hazard class label(s) is required on the outside of the package. These are the diamond-shaped labels that display the appropriate hazard class number, symbol, and, if applicable, division number.
2. Meet all markings requirements. Markings may refer to the UN number and proper shipping name, as well as other information such as limited quantity and overpack. Review both the specific packing instruction and the marking section in the regulations to ensure you meet all requirements.
3. Select the appropriate UN specified packaging. It is imperative to understand the UN specification markings on the packaging selected. Also, verify the packaging is specifically authorized for the type and quantity of DG intended and via the transport mode you select.
4. Train employees. Be sure to train everyone involved in the shipping process. In the United States, 49 CFR 172.700-704 specifies the basic mandatory training required for dangerous goods shippers.
5. Ensure proper documentation. Shipping papers should include required product information for people further down the transport chain. Ground transport into the United States requires DG information to be recorded on the bill of lading. Shipping by air or ocean carrier under International Civil Aviation Organization (ICAO) or IMO regulations usually requires a specific dangerous goods declaration.
6. Verify criteria. When shipping radioactive materials, verify the package meets the specified performance criteria for the type of material in question.
7. Classify dangerous goods. Review section 14 (transportation) of the product’s safety data sheet. If the product has already been classified, the information will likely be there. If not, contact the original manufacturer, who is required to have this information.
8. Determine the correct set of rules. When shipping by ground in the United States, the right set of rules is almost certainly the 49 CFR parts 100-185. When shipping by air, the ICAO technical instructions, or one of its derivations, is most often the correct choice. When shipping by ocean carrier, refer to the International Maritime Dangerous Goods Code.
9. Determine if you need a placard. If the load is large, or contains certain DG, placarding may be required for the vehicle and/or container where the DG is loaded.
10. Certify the shipment is compliant. The signer avows the shipment is correct, safe, and fully compliant. The consequences of non-compliance can endanger life and property, and lead to legal action.