Behind the Hazmat Regs

The difference between someone's life or death may be having the proper papers, properly filled out. Know the rules.

• By Randy Skoog
• Sep 01, 2003

WHEN a hazardous materials accident occurs, time is a precious commodity. How long it takes responders to secure the scene could mean the difference between life and death.

It is important that each and every step necessary in the hazmat transportation process has been taken to ensure responders have the information needed to do the best job possible, in the shortest amount of time. A number of questions need to be answered before a shipment of hazardous materials heads out on the highway:

Has everyone in the hazmat transportation process been thoroughly trained? Has the shipment been properly prepared, with all of the necessary documentation? In an emergency situation, will the documentation be readily available and easy to understand?

The hazmat shipping paper and the emergency response information accompanying it require careful preparation. What follows is a look at some of the steps needed to prepare the necessary documentation, keeping in mind that what is done during the process could really make a difference.

The HMR
Plain and simple, the Hazardous Materials Regulations (HMR) detail what is required by the federal government to ship hazardous materials in commerce. But the HMR is much more than that.

Many of the requirements in the HMR are there to provide important information to responders in the event an incident occurs. Just in case a bulk shipment of gasoline is involved in a pileup. Just in case something really bad does happen. With many hazmat shipments, the potential is there.

The manner in which the HMR is written guides the preparation of hazardous materials shipments so that, in the event of an emergency, responders are able to identify the hazmat involved and the hazard(s) associated with it. It is more than just having to comply with the regulations. The regulations really do serve a purpose.

Hazmat training
Hazardous materials training is required and detailed in 49 CFR 172 Subpart H. How an employee is trained is going to depend on that employee's job function. Each employee must understand his or her hazmat job function and why it is important that it be done correctly, every time it is performed.

Rather than thinking it's just part of the job, employees need to know why a shipping paper has to be filled out correctly and why the proper label or placard needs to be used. They need to know someone's life could depend on it.

Shipping papers
Shipping papers are one of the first things emergency personnel will look for when arriving at the scene of a hazmat incident. How the papers are filled out and where they are located will help to determine that crucial first step of response.

In order, each description of a hazardous material on a shipping paper must have:

• The proper shipping name of the material;
• The hazard class;
• The identification (ID) number; and
• The Packing Group (PG).

The total quantity, including the unit of measurement, also must be included, in association with each shipping description of a hazardous material.

It's important that the hazardous materials listed on the shipping paper stand out. Hazmat must be:

• Listed first;
• Entered in a color that clearly contrasts with any non-hazmat description on the shipping paper; or
• Identified by an "X" in a hazmat or "HM" column.

Why are these steps important? By clearly listing the proper shipping name, hazard class, ID number, packing group, and total quantity, trained responders will instantly recognize what kind of hazardous material they are dealing with, how much, and what needs to be done.

Most shipping papers also are required to have a telephone number for use if an emergency involving hazardous materials occurs. The emergency response telephone number must be the number of the person offering the hazardous material for transportation or an agency that is capable of, and accepts responsibility for, providing detailed emergency response information about the hazmat on the shipping paper.

The number must be entered immediately following the description of the hazardous material on the shipping paper or entered once in a visible location on the shipping paper, indicating it is for emergency response information.

In an emergency, the number may be called by response personnel to get specific information about the hazardous material involved. That's why it is important that the number be monitored at all times while the hazmat shipment is being transported.

Emergency Response Information
Most shipments of hazardous materials requiring shipping papers must be accompanied by emergency response information. At a minimum, the information must contain:

• The basic description and technical name of the hazmat.
• Immediate hazards to health.
• Risks of fire or explosion.
• Immediate precautions to be taken in the event of an accident or incident.
• Immediate methods for handling fires.
• Initial methods for handling spills or leaks in the absence of fire.
• Preliminary first aid measures.

The information must be complete, printed legibly, in English, and available for use away from the hazmat package(s).

There are a number of ways to provide the emergency response information. The most common include:

• Listing it directly on the shipping papers.
• Keeping a copy of the Emergency Response Guidebook (ERG) with the shipping papers.
• Keeping a copy of the appropriate guide page from an ERG with the shipping papers (the hazmat's basic description and technical name, if any, must be included).
• Keeping a copy of the hazmat's Material Safety Data Sheet (MSDS) with the shipping papers (the hazmat's basic description and technical name, if any, must be included).

The ERG was developed by the federal government to enable first responders at the scene of a hazmat emergency to quickly identify each hazardous material and the hazards present. MSDSs list known hazard and protection information required by the Occupational Safety and Health Administration for a specific chemical or material. The HMR requires that an MSDS attached to the shipping paper contain all of the required emergency response information listed.

Location, Location, Location
Where the shipping papers and emergency response information are kept is as important as the papers themselves. Response personnel must be able to locate the necessary documentation quickly, in order to determine which steps may need to be taken. Time lost trying to find or access that information during an emergency could be costly.

Authorities must be able to access and recognize shipping papers and emergency response information in the event of an accident or incident. The HMR requires that the hazmat shipping paper be clearly distinguished if carried with other papers, by either having it appear first or by tabbing it.

When the driver is at the vehicle's controls and restrained by a lap belt, the hazmat shipping papers and emergency response information must be within immediate reach. They should be readily visible to anyone entering the cab or located in a holder mounted to the inside of the driver's door. When no one is at the controls, the shipping paper and emergency response information should be on the driver's seat or located in a holder mounted to the inside of the driver's door, whether the door is locked or unlocked.

Facility operators where hazmat is received, stored, or handled during the transportation process must keep the shipping papers and emergency response information accessible to facility personnel in the event of an incident.

Making a Difference
Emergency response involving hazardous materials can be a complex operation, depending on the severity of the accident/incident and which hazmat is involved. Working in unfavorable conditions when time is never on their side, responders face challenges that go beyond anything many of us will ever witness. Taking time to train employees to ensure shipping papers and emergency response information are correct and properly located is time well spent. It could save someone's life.

This article originally appeared in the September 2003 issue of Occupational Health & Safety.