Hazmat Requirements: 12 To Check Off To Ensure Compliance

September 17, 2020

The Federal Motor Carrier Safety Administration (FMCSA) dedicates an entire section in its rulebook to hazmat requirements. To summarize, the agency emphasizes safety, safety, safety. Hazmat freight can be profitable. Before you haul hazmat freight, though, it’s a good idea to get clear on these safety directives. This article will help you answer these questions:

• How can you ensure you’re in hazmat compliance?
• What information is required on hazmat documents?
• Can you digitize hazmat documents?

Here’s a checklist of the 12 critical hazmat requirements you need to ensure compliance. Meanwhile, the freight industry is moving to paperless, digitized documents. Thus, we’ll highlight how digitized document technology can streamline your drivers’ workflow and hazmat paperwork.

The Critical Hazmat Paperwork Requirement Checklist

First of all, our list covers the high-level information your shipping paperwork must include to ensure hazmat compliance. Here’s what we’ll cover:

1. Hazmat class designations
2. Hazmat placards
3. The basic description of hazmat freight: ISHP
4. Other information included in the shipping description
5. Additional descriptions: further hazmat requirements
6. Emergency response telephone number
7. Emergency response information
8. Signed shipper’s certification statement
9. Hazmat shipping paperwork requirements of shippers, drivers, and carriers
10. Reporting hazardous materials incidents
11. Digitized documents that may help mitigate spread of Class 6 infectious substances
12. Hazmat requirements for paperwork retention and record keeping

When it comes to hazmat, the FMCSA defers to the Code of Federal Regulations (CFR) Title 49: Part 172: Subpart C. This regulatory document essentially controls the details of compliant hazmat shipments. After you read it, you’ll further understand the level of detail required on hazmat shipping documents.

In addition, you may realize how much digitized documents help to streamline driver workflow as well as reduce the risk of incorrect documentation.

1. Identify the Hazmat Classes

Hazardous materials are organized into classes according to the level of risk associated with each material. These nine hazardous material classifications are consistent across all agencies involved with the regulation of commercial shipping. The classes are:

• 1: Explosives
• 2: Gases
• 3: Flammable liquids
• 4: Flammable solids
• 5: Oxidizers or organic peroxides
• 6: Toxic and infectious substances
• 7: Radioactive material
• 8: Corrosives
• 9: Miscellaneous hazardous materials

In addition, each class of hazmat has various subclasses—as well as its own hazmat placard.

2. Identifying the Hazmat Placards

Because hazmat placards identify the class of freight being transported, they must be correct and visible at all times. If there’s an accident or hazmat incident, then these placards are essentially the first thing emergency responders look for. Furthermore, hazmat placards indicate the protocol first responders will follow. So, here’s a link that lets you see what each class looks like.

In addition to placards, other hazmat paperwork requirements help emergency workers and communities manage hazmat emergencies ahead of time. So that’s what we’ll dive into next!

3. The Basic Description of Hazmat Freight: ISHP

Next, you should understand the basic description within hazmat paperwork. The FMCSA requires you to present this basic description of the hazmat freight in the proper, specific sequence. It offers the acronym ISHP to help you remember the correct sequence of the basic hazmat description:

• First, the Identification number according to the Hazardous Materials Table
• Next, the proper Shipping name of the hazardous material
• After that, the Hazmat class (and subsidiary hazard class where applicable)
• Finally, the Packing group (which defines the material’s level of danger as low, medium, or high)

4. Other Information Included in the Shipping Description

After that, the section of hazmat paperwork requirements lists “Other Information.” This includes:

• The technical name of the hazardous material (such as flammable liquids, radioactive waste, and so on)
• The number and type of packages holding the hazardous contents (for example, 10 drums)
• Total quantity of hazardous materials by mass or volume (for instance, 50 gallons)
• Net explosive mass, if applicable
• EX-number, if applicable

5. Additional Descriptions: Further Hazmat Requirements

What else do you need to specify? The government requires the following additional descriptions wherever they apply.

• Last contained material (required for tank car with residue from prior loads)
• Marine pollutant risk
• “Poison-inhaled hazard” or “Toxic-inhalation hazard” label
• DOT special permit or exemption number
• Limited or reported quantity
• “HOT” (for liquids or molten solids with elevated temperature)

6. Emergency Response Telephone Number

Next, the emergency contact phone number is one of the most critical hazmat requirements. People will use this number only if there’s a hazmat emergency. Thus, the person monitoring the emergency number must know the hazardous material emergency procedures to help first responders.

Obviously, this number must be clearly visible and easily located on the paperwork. Include the international access code where needed.

7. Emergency Response Information

After you list the phone number, you must include immediate emergency response instructions on the hazmat shipping paperwork. (Or you can attach them to the paperwork.) Why? This information guides the emergency response at the scene of a hazmat emergency. Therefore, it must include these points.

1. The ISHP basic description, including technical name
2. Immediate hazards to health
3. Risks of fire or explosion
4. Immediate precautions to take after an incident or accident
5. Immediate methods for handling fires, spills, or leaks
6. Preliminary first aid measures

8. Signed Shipper’s Certification Statement

Once you have completed the contact information and instructions, you’re ready to provide evidence of certification. A shipper’s certification statement confirms that all the information in the document is correct. A principal, officer, partner, or employee of the shipper or the shipper’s agent signs the hazmat cert statement. Traditionally, this person has signed manually. However, nowadays he or she can sign digitally. The following is a common example of a shipper’s certification statement:

“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.”

9. Hazmat Shipping Paperwork Requirements of Shippers, Drivers, and Carriers

What’s next? Hazmat freight requirements dictate that compliant shipping paperwork must be available to the driver and carrier at all times during transport. The carrier must have and maintain a printed copy of this information until delivery of the hazardous materials. Regardless, I highly advise you to back this up with digitized documents. We’ll discuss this further in the next section.

Specifically, it’s the shipper’s duty to provide the correct hazmat paperwork—unless the carrier agrees to prepare the paperwork on behalf of the shipper. Before the driver hits the road, both the carrier and shipper must verify the accuracy of the information on the paperwork.

Once the driver is inside the truck, he or she must keep the hazmat shipping paperwork within reach while his or her seat belt is on. In addition, the driver’s hazmat paperwork must be visible to any first responder that enters the vehicle. In the long run, the “visible hazmat paperwork for first responders” may be the last document in freight that requires a paper copy.

That said, if and when—heaven forbid—there’s an accident involving hazmat material, there’s another process to follow.

10. Reporting Hazardous Materials Incidents

After a hazmat incident, you must report in as soon as possible. In general, you must report a hazmat incident less than 12 hours after it happens. The person in physical possession of the hazardous material must call the National Response Center (NRC) at 800-424-8802 and prepare a report. For example, each report must include the following information:

• First, the name, address, and phone number of reporter
• Next, the date, time, and location of incident
• After that, the basic ISHP description of hazardous material involved
• Next, the extent of any injuries
• And finally, the type of incident, nature of hazardous material involvement, and whether a continuing danger to life exists at the scene

Any of the following hazmat-related occurrences requires an official report:

• A person is killed
• Any person receives an injury requiring admittance to a hospital
• The general public is evacuated for one hour or more
• A major transportation artery, or a facility, is closed or shut down for one hour or more
• The operational flight pattern or routine of any aircraft is altered
• Fire, breakage, spillage, or radioactive contamination occurs involving a radioactive material or an infectious substance
• A release of a marine pollutant occurs in a quantity exceeding 450 liters (119 gallons) for a liquid or 400 kilograms (882 pounds) for a solid
• During transportation by aircraft, a fire, violent rupture, explosion, or dangerous evolution of heat occurs as a direct result of a battery or battery-powered device

Any hazmat incident has the potential to trigger a DOT audit. It’s worth noting that digitized documentation can help streamline your audit preparation process.

11. Digitized Documents May Help Mitigate Spread of Class 6 Infectious Substances

In reality, digitized documents now define the freight industry. In addition, digitized documents are just practical. Compared to paper, they’re highly efficient. Speaking of safety, digitized documents are actually the darling of risk mitigation. That’s because they facilitate touchless, contactless freight transactions. That maintains social distancing measures, which helps control the accidental spread of Class 6 hazmat freight, such as life-threatening infectious diseases.

In the paperless, digitized freight-document arena, Vector is the leading tech company. Consider adding Vector’s name to your hazmat checklist. The customizable digitized document software Vector created saves, time, money, and many, many trees.

12. Hazmat Requirements for Paperwork Retention and Record Keeping

The requirements of hazmat paperwork retention are an area where digitized documents can really shine. With hazmat, you must retain many documents for long periods. In addition, you must promptly produce hazmat shipping paperwork when an authorized official requests it.

Hazmat shipping paperwork must be accessible through the shipper’s and carrier’s principal place of business. In addition to that, shippers and carriers must retain a copy of the required hazmat shipping paperwork, or an electronic image thereof, for the time frames listed below:

1. All hazardous material freight: The carrier must keep shipping papers for one year after they accept the freight.
2. Hazardous material freight (other than hazardous waste): The shipper must retain paperwork for two years after the carrier accepts the material.
3. Hazardous waste freight: The shipper and carrier must keep the shipping paper work for three years after they accepted the material.

In other words, freight companies must retain the records of each hazmat shipment or a long time. And the best practices of document storage indicate that the best way to organize this volume of data is digitally.

Closing Thoughts and Digitized Hazmat Documents

Hazmat freight can be good, profitable freight. Yes, there’s a lot of paperwork involved. And in the event of an emergency, it has the potential to be very bad. But as long as you do everything right and take the correct safety precautions, hazmat can remain profitable.

Bear in mind, accidents aren’t the only risk to hazmat carriers. Indeed, the FMCSA carefully governs hazmat freight. The DOT regularly performs compliance reviews, security audits, and hazmat audits on carriers and drivers. But as with any audit, the pain involved with a hazmat audit directly relates to your level of document organization.

To sum up, when it comes to hazmat requirements, the message is simple. Hazmat-related violations can result in hefty fines or even a shutdown. And that in turn can result in a catastrophic profit loss!

Whether you’re the owner of the company, driver, fleet manager, or back office manager, use the best digitized document software on the market to reduce the potential risk of hazmat freight.

This post was written by Brian Deines. Brian believes that every day is a referendum on a brand’s relevance, and he’s excited to bring that kind of thinking to the world of modern manufacturing and logistics. He deploys a full-stack of business development, sales, and marketing tools built through years of work in the logistics, packaging, and tier-1 part supply industries serving a customer base comprised of Fortune 1000 OEMs.