Hazmat Essentials: All About Hazard Class 9

In a recent video, we talked about all nine classes of hazardous materials regulated around the world (and their divisions).

Now let's take a closer look at Hazard Class 9. The "miscellaneous" hazard class includes materials like lithium batteries, asbestos fibers, many hazardous wastes, marine pollutants, and a whole lot more that doesn't fit into any other hazard class 1 through 8.  

Watch the video and subscribe on YouTube to catch the next one: 

Types of Class 9 Hazmat

This video gives you the details about the six types of materials that can be Class 9 hazmat:

• "DOT Says So."
• Airplane hazards.
• Hazardous wastes.
• Hazardous substances.
• Marine pollutants.
• Elevated temperature materials 

Because "DOT Says So"

This category refers to materials that do not fit the criteria to be included in any hazard class 1 through 8. Still, US DOT has determined that the material poses some kind of hazard in transportation that necessitates regulations to ensure safety and protect the public. Lithium batteries are regulated as Class 9 hazardous materials "because DOT says so," for example.

Class 9 "Airplane Hazards"

These are hazardous materials with the potential to cause a dangerous situation aboard an aircraft. Self-defense spray, i.e., "pepper spray," is one example.

There have unfortunately been several cases of passenger flights forced to make emergency landings after pepper spray or a similar self-defense product was dispersed on board. In 2023, a Miami, Florida-bound flight from New York’s LaGuardia Airport was forced to divert and make an emergency landing after a passenger accidentally discharged pepper spray in the cabin.

A flight from Oakland to Hawaii in 2018 turned “harrowing” when pepper spray carried on board by a passenger dispersed mid-flight. With no good options for an emergency landing in this case, several passengers were injured by the time the flight landed.

Class 9 Hazardous Wastes

For the purpose of compliance with the US DOT/PHMSA Hazardous Materials Regulations (HMR), a hazardous waste is defined in 49 CFR 171.8 to mean:

“...any material that is subject to the Hazardous Waste Manifest Requirements of the US Environmental Protection Agency specified in 40 CFR part 262.”

Hazardous wastes that do not fit the criteria for inclusion in any hazard class or division 1 through 8 are classified as Class 9 for transportation.

Class 9 Hazardous Substances

“Hazardous substances,” in this context, are materials listed by US EPA in the regulations implementing CERCLA/Superfund. The list of hazardous substances is found in 40 CFR Part 302.4, and each listed substance is paired with a reportable quantity or “RQ.”

The RQ is the amount of a material that, if released, requires immediate to the National Response Center or NRC.

Potential Reportable Quantities (RQs) for a hazardous substance are:

• 1 pound (.454 kg)
• 10 pounds (4.54 kg)
• 100 pounds (45.4 kg)
• 1,000 pounds (454 kg)
• 5,000 pounds (2270 kg)

The greater the threat posed to human health and the environment, the lower the RQ for that material.

Class 9 Marine Pollutants 

A “marine pollutant” is a material that, if released, endangers animals and plants that live in water. US DOT/PHMSA lists potential marine pollutants (MPs) in an Appendix to the Hazmat Table in 49 CFR 172.101.

For the purpose of transportation under the HMR, a material listed in the 172.101 appendix is a marine pollutant when:
 

a solution or mixture of one or more marine pollutants, is packaged in a concentration which equals or exceeds:  (1) Ten percent by weight of the solution or mixture for materials listed in the appendix; or (2) One percent by weight of the solution or mixture for materials that are identified as severe marine pollutants in the appendix." [49 CFR 171.4 and 171.8]

What is a Severe Marine Pollutant (S.M.P.)?

Materials that pose the greatest threat to aquatic life are designed by DOT as severe marine pollutants (S.M.P.). A few examples of severe marine pollutants include mercury compounds, PCBs, and certain pesticides and herbicides (chlorpyriphos, DDT).

On the list of marine pollutants appended to §172.101, the symbol “PP” appears next to each severe marine pollutant.

Note on Vessel Transportation (IMDG Code) 

International hazardous materials/dangerous goods regulations define marine pollutants differently than US DOT. The International Maritime Dangerous Goods Code (IMDG Code) lists regulated goods in Chapter 3.2. On that list, marine pollutants are identified with a "P" symbol. Also, additional marine pollutants are listed in the index to the IMDG Code. 

Class 9 HOT Materials 

Some materials are shipped at a high temperature to facilitate loading, transportation, transloading, and unloading. A material like concrete, for example, is typically shipped at hundreds of degrees Fahrenheit. This keeps the material pourable and pumpable. At a cooler temperature, it would harden to rock inside of the motor vehicle. 

Because being physically "hot to the touch" is not one of our recognized hazard classes or divisions 1—8, this type of "HOT" material is regulated as a Class 9 in transportation. 

What Do We Know About Class 9 Hazmat?

Recap: After watching the video and/or reading the article above, we know the following about Class 9 hazardous materials: 

• Class 9 materials pose some known hazard in transportation
• Class 9 materials do not fit the criteria for any Hazard Class or Division 1–8
• Class 9 materials fit into one of six categories described in the video/blog: 1) DOT Class 9's, 2) airplane hazards, 3) hazardous wastes, 4) hazardous substances, 5) marine pollutants, and 6) HOT materials. 

Lastly, Class 9 is among the most transported classes of hazmat in the US. According to recent data from the US Census Commodity Flow Survey (CFS) showed about 70 million tons of Class 9 hazmat transported in the US for the given year.

From now on, you will know a Class 9 hazardous material when you see one. 

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More about shipping hazardous substances and "RQ": 

• When to Indicate RQ for Hazmat Shipments 
• Reporting Hazmat Transportation Incidents
• Alfredo Sauce: A Reportable Release? 

Online Hazmat Shipper Training

Develop a step-by-step process to identify and apply the US and international regulations that apply to hazmat shipments offered for transportation by ground, air, or vessel.

Check out all of our online courses including hazmat shipper training, or jump right to the hazmat shipping online course that you need below.

Hazmat Ground Shipper Certification (DOT)
Hazmat Air Shipper Certification (IATA)
Hazmat Vessel Shipper Certification (IMDG)
Shipping Lithium Batteries

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