Building the Perfect Hazmat Basic Description

The shipping paper is one of the most important documents in the hazmat shipping process. Call it a bill of lading, declaration, IMO, Shipper’s Dec, manifest, or whatever you want—it’s a certified written record of what is being shipped, the hazards present, how much is there, and where to go for more information. [49 CFR 172, Subpart C]

Because this document is used to communicate information that has the potential to prevent catastrophe and even save lives in the event of a hazmat incident, it is crucial that you know how to fill it out completely and accurately. That starts with crafting the perfect basic description for the hazardous material or article you need to ship.

What’s in a DOT Hazmat Basic Description?

The hazmat Basic Description is the core element of the shipping paper. For each hazardous material in a shipment, the shipping paper must include a description. Every basic description must include the following elements, in order and with minimal variation [49 CFR 172.202(a)]:

1. Identification Number (e.g., UN1993, ID8000, NA3082)
2. Proper Shipping Name (may need to supplement with technical name)
3. Hazard Class or Division number with subsidiary Hazard Class or Division number in parentheses (if applicable)
4. Packing Group (by roman numeral, if applicable)

If you’ve worked in hazmat shipping for a few years, you may remember a different order for these basic description elements. But since January 1, 2013 the new basic description order listed above is mandatory. If you use an automated system designed before 2013 to create your basic descriptions, check to ensure that the system outputs the elements in the correct order.

Where to Find the Hazmat Basic Description Elements in 49 CFR

You can find all of the pieces of information above in the Hazardous Material Table at 49 CFR 172.101. Often, useful information for basic descriptions can also be found on a Safety Data Sheet (SDS). That said, before using an SDS for basic description information, make sure the what’s on your SDS is accurate and complete.

Identification numbers and Proper Shipping Names are paired in the 172.101 Table. One ID number may be associated with multiple proper shipping names, but each Proper Shipping Name will only ever be associated with one number.

There are three packing groups (I, II, and III), but articles, gases, and certain other materials aren’t assigned packing groups.

Modifying Your Basic Description—What Is Allowed?

While the order of hazmat basic description elements is hard-and-fast, DOT does allow shippers to take some poetic license with how they communicate the basic description on shipping papers. The following are all DOT-approved modifications to hazmat basic descriptions:

• You may, but do not have to, write the word “CLASS” or “DIVISION” preceding the number in the description. (e.g., UN1790; Hydrofluoric acid; Class 8 (Division 6.1); II).
• You may, but do not have to, write the name(s) of the hazard class(es) or division(s) after the number itself, or at the end of the basic description. (e.g., UN1203, Gasoline, 3 Flammable liquid, PG II>or UN 1203, Gasoline, 3, II, Flammable liquid)
• You may, but do not have to, write “PG” preceding packing group numeral in the description.
• You may, but do not have to, include the italicized text after the Roman type Proper Shipping Name as listed in the Hazardous Material Table at 49 CFR 172.101. (e.g., Paint related material including paint thinning, drying, removing, or reducing compound may simply be called Paint related material).
• You may, but do not have to, include appropriate modifiers such as “contains” or “containing” and/or the percentage of the constituent the actual percentage instead of the range as listed in the table. (e.g., UN1993; Flammable Liquids, n.o.s.; 3; PG II (containing xylene and heptane) or UN1993; Flammable Liquids, n.o.s. (15% xylene and 15% heptane); 3; PG II).

Additional Information in Hazmat Basic Descriptions

We’re not done with basic descriptions yet! DOT also requires additional information that must appear “in association with” your hazmat basic description. “In association with” means appearing on the shipping paper either before or after the basic description.

Info that must appear in association with the basic description on all shipping papers:

• Total quantity of material required [49 CFR 172.202(a)(5)]
• Number and type of packagings required [49 CFR 172.202(a)(7)]

When applicable, DOT requires the following pieces of information to appear in association with the basic description for certain materials:

• Technical names for generic Proper Shipping Names (“G” in column 1 of the Hazardous Material Table). [49 CFR 172.203(k)] For a mixture or solution with two or more hazardous materials, include the technical names of at least two components most predominately contributing to the hazards.
• The letters “RQ” for hazardous substances. [49 CFR 172.203(c)]
• The words “RESIDUE: LAST CONTAINED ***” are mandatory for empty tank cars, optional for all other packagings. [49 CFR 172.203(e)]
• The words “MARINE POLLUTANT” for marine pollutants [49 CFR 172.203(l)]
• “Poison-Inhalation Hazard” or “Toxic-Inhalation Hazard” and hazard zone for materials poisonous by inhalation. [49 CFR172.203(m)]
• The word “waste” for hazardous wastes as defined in 49 CFR 171.8 unless the word "waste" is already a part of the name. [49 CFR 172.101(c)(9)]

There are even more requirements for more specific materials. See 49 CFR 172, Subpart C for details. Most of the time, information must appear “in association with” the basic description. Sometimes the additional words must be inside the description, or only before, or only after, or may go before and after. The specific provisions will explain themselves.

Basic Descriptions for Elevated-temperature Materials and Limited Quantities

There are two special situations that require you to include specific wording associated with your basic description:

• Elevated-temperature materials must have the word “HOT” either immediately BEFORE or AFTER the Proper Shipping Name within the basic description. [49 CFR 172.203(n)]
• On the rare occasion that shipping papers are required for limited quantity shipments, the words “LIMITED QUANTITY” or “LTD QTY" must appear FOLLOWING the basic description.[49 CFR 172.203(b)]

Understanding the elements required in a basic description, and knowing what order to list them in, is a crucial part of shipping hazmat. This information is critical to professionals throughout the supply chain, not least of all the first responders who answer the call in the event of a hazmat incident.

In addition, getting your basic description right will protect your business from some of the most common reasons for DOT hazmat penalties. Civil penalties for hazmat shipping mistakes are now as high as $77,114 per day, per violation.

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Tags: 49CFR, DOT, hazmat shipping, PHMSA, shipping papers