The Hazardous Materials Table, or HMT, is the backbone of the
Hazardous Materials Regulations. Understanding and knowing how to use the HMT is
the first step toward compliance.
For each material listed, the 172.101 Hazardous Materials Table
identifies each hazard class or specifies that the material is forbidden in
transportation. It provides the proper shipping name of the material or directs
the user to the preferred proper shipping name. In addition, the HMT specifies
or references requirements pertaining to labeling, packaging, quantity limits
aboard aircraft, and stowage of hazardous materials aboard vessels.
The Hazardous Materials Table usually referred to as the HMT or
the Table, governs the transportation of hazardous materials by all modes air,
water, rail and highway. It is important to use the Hazardous Materials Table
correctly.
Column (1)
may contain any one of six symbols: a plus sign(+) or the capital letters "A",
"D",
"G", "I", and "W".
(1) Symbols
(+, A, D, G, I or W) |
|
-
The plus (+) sign fixes the proper shipping name,
hazard class and packing group listed in Columns 2, 3, and 5, of the HMT.
“Fixes” means you may not change the proper shipping name, hazard class, or
packing group, even if the materials do not meet that hazard class
definition. When the “+” sign is assigned to a proper shipping name in
Column 1 of the HMT it means that the material is known to pose a risk to
humans. The Associate Administrator for Hazardous Materials Safety may
authorize an appropriate alternate proper shipping name and hazard class.
-
The letter “A” in Column 1 means that the specific material
is only regulated if offered or transported by aircraft, unless the material
is a hazardous substance or a hazardous waste. Hazardous substances and/or
hazardous wastes are regulated in all modes of transportation. A shipping
description entry preceded by the letter “A” may be used to describe a
material for other modes provided all applicable requirements are met.
-
The letter “D” identifies the proper shipping names, which
are appropriate for describing materials for domestic
transportation but may be inappropriate for international transportation
under the provisions of international regulations (e.g., IMO, ICAO). An
alternate proper shipping name may be selected when either domestic or
international transportation is involved.
-
The letter “G” identifies n.o.s. (not otherwise specified)
and generic proper shipping names for which one or more technical names of
the hazardous material must be entered in parentheses, in association with
the basic description.
-
The letter “I” identifies proper shipping names, which are
appropriate for describing materials in international transportation. An
alternate proper shipping name may be selected when only domestic
transportation is involved.
-
The letter “W” in Column 1 means the specific material is
regulated only if offered or transported by vessel, unless the material is a
hazardous substance or a hazardous waste. Hazardous substances or hazardous
wastes are regulated in all modes of transportation.
Column 2 of the HMT contains proper shipping names are found
in Column 2. Look closely at the two types of
lettering, Roman and Italic. Proper shipping names are written in Roman type
only. It is critical that the proper shipping name be spelled correctly on
shipping papers. Proper shipping names in italics may not be used to describe
hazardous materials.
(2) Hazardous
Material Description and Proper Shipping Name: |
Benzoquinone |
Words in italics are not part of the proper shipping name, but
may be used in addition to the proper shipping name. Find the proper shipping
name Blue asbestos. Notice the entry Blue asbestos or Brown asbestos. The
italicized or means that any of the terms in the sequence may be used as part of
the proper shipping name, as appropriate.
The word “see” after a proper shipping name entry refers to
another entry. If both names are in Roman type, you may use either name as the
proper shipping name. Find the shipping name “Ethyl alcohol.” Notice that “Ethyl
alcohol” is in Roman type and has no hazard class or division or identification
number. However, the italicized word “see” refers you to “Ethanol;” Find
“Ethanol.” This is where the hazard class or division and the ID No. are
located. You may use either “Ethyl alcohol” or “Ethanol” as the proper shipping
name since both names are in Roman type.
The words “poison” or “poisonous” may be used interchangeably
with the word “toxic” when only domestic
transportation is involved. When international transportation is involved, only
the word “toxic” may be used.
The
name on this drum. "Flammable liquids, n.o.s."
Is it a proper shipping name? Yes, “Flammable liquids, n.o.s.”
is listed in Column 2 of the HMT in Roman letters and is a proper shipping name.
Except for hazardous waste, when qualifying words are utilized
as part of the proper shipping name, their sequence in
the package markings and shipping paper description is optional; however, the
entry as shown in the HMT is the
preferred sequence. Qualifying words shown in italics are not part of the proper
shipping name. For example, for the entry “Paint related material including
paint thinning, drying, removing or reducing compound, 3, UN 1263, PG I”, the
qualifying words shown in italics are not required to be shown as part of the
proper shipping name.
When the material is a hazardous waste and the word “waste” is
not included in the HMT description, the word “waste” must be placed before the
proper shipping name. For example, Acetone would become Waste Acetone. The word
“waste” need not precede a proper shipping name that already includes the word
“waste”. “Hazardous waste, liquid, n.o.s.” or “Hazardous waste, solid, n.o.s.”
are two examples that do not
require the addition of the word waste.
Under certain conditions, a mixture or solution not identified
specifically by name, comprised of a hazardous material identified in the HMT by
technical name, and a non-hazardous material, must be described using the proper
shipping name of the hazardous material and the qualifying word “mixture” or
“solution”, as appropriate
Column 3 of
the HMT contains a designation of the hazard class or division corresponding to
each proper shipping name, or the word “Forbidden”. Forbidden means that the
material may not be offered for transportation or transported. This prohibition
does not apply if the material is diluted, stabilized, or incorporated in a
device, and it is classed in accordance with the definitions in Part 173 of the
HMR. When test data or new data indicates a need to modify the “Forbidden”
designation, the data must be submitted to the Associate Administrator for
Hazardous Materials Safety for approval.
(3) Hazard
Classification |
6.1 |
The hazard class of a hazardous material is indicated either by
its class (or division) number, its class name, or by the letters “ORM-D”. The
table contained in 173.2 lists the class numbers, division numbers, class or
division names and those sections of the subchapter, which contain definitions
for classifying hazardous materials, including forbidden materials.
When the entry for combustible liquids in Column 3 references
Class 3, each reference to a Class 3 material must be modified to read
“Combustible liquid” when reclassed in accordance
with 173.150(e) or (f).
Column 4 of the HMT lists the 4digit identification
number assigned to each proper shipping name. These 4digit numbers provide quick
identification of all hazardous materials. It is critical to emergency
responders that the numbers are accurate and that they are correctly written and
legibly displayed.
(4)
Identification Numbers |
UN2587 |
Identification numbers preceded by “UN” for United Nations are
descriptions of materials for domestic and/or international shipments, while
identification numbers preceded by “NA” for North America may be used to
describe certain materials when transported within the United States or between
the United States and Canada.
Column 5 of the HMT specifies one or more packing groups
assigned to a hazardous material. If a material is assigned to more than one
packing group, the shipper must determine the correct packing group for the
hazardous material. The packing group of the hazardous material will have an
effect on a material’s packaging requirements. This grouping is according to the
relative degree of danger presented by the hazardous material. Packing Group One
indicates the greatest danger, while Packing Group Two indicates a medium level
of danger, and Packing Group Three indicates a minor level of danger.
(5) Packing Group
(PG)
I-Great Danger
II-Medium Danger
III-Minor Danger |
II |
The packing group number must be indicated in Roman numerals on
shipping papers, when applicable, and may be preceded by the letters “PG.” There
are no packing groups for Class 2, Class 7, Division 6.2, and ORMD materials.
On shipping papers, the hazardous material must be accurately
described and identified in the proper sequence with the proper shipping name (
including the technical name, when
applicable), the hazard class or division, the ID number, the packing group
(when applicable); and the total quantity. All shipping papers must describe the
hazardous materials in this sequence: the proper shipping name, the hazard class
or division, the ID number, the packing group, and the total quantity. These
five items make-up the basic description.
Column 6 of the HMT specifies label codes, which
represent the hazard warning labels required to be applied to each package of
hazardous material, unless excepted. If two label codes are listed, the first
represents the primary hazard and the second represents the subsidiary hazard.
Additional labeling requirements are found in 172.402.
Column 7 of the HMT specifies codes for special
provisions applicable to packaging, packaging requirements, certification, and
marking or labeling for a hazardous material. These special provisions are in
addition to the standard packaging requirements.
(7) Special
Provisions (172.102)
|
IB8, IP2, IP4 |
Column 8 of the HMT specifies the applicable sections for
packaging authorizations. Notice that Column 8 is divided into three parts -
Column 8A, 8B and 8C. The sections cited under Columns 8A, 8B, or 8C are found
in Part 173.For example: the number “211” in column 8B indicates that the
specific nonbulk packaging requirements are found in 173.211. Also, the number
“242” in Column 8C indicates that the specific bulk packaging requirements
are found in 173.242.
(8A) Packaging
Exceptions (173.***)
|
None |
(8B) Packaging
(Non-Bulk) (173.***)
|
212 |
(8C) Packaging
(Bulk) (173.***)
|
242 |
When the packaging reference is not applicable to the form
(solid or liquid) of the material being transported, use the Solid/Liquid Table
in 172.101(i)(4) to determine the correct packaging.
Column 9 is divided into two columns and prescribes the
maximum quantity limits for hazardous material transported in one package by
either a passenger carrying aircraft or rail car, or by a cargo aircraft only.
(9A) Passenger
Aircraft
|
25 kg |
(9B) Cargo
Aircraft Only
|
100 kg |
Column 10, “Vessel Stowage,” is divided into two parts.
Column 10A specifies the authorized stowage locations for hazardous materials on
cargo and passenger vessels. Column 10B specifies vessel stowage requirements
for specific hazardous materials. For more information about Column 10 and the
five authorized stowage locations, please review Section 172.101(k).
(10A) Vessel
Storge (Location)
|
A |
(10B) Vessel
Storage (Other)
|
|
Hazardous materials often fit more than one category, such as
hazardous substance, marine pollutant, and hazardous waste. For example,
Acetone, a Class 3 flammable liquid material is listed in Table I to Appendix A,
and may meet the definition of a hazardous substance. Review 171.8 for more
information on the definition for a hazardous substance.
Hazardous substances are listed in Table I -
Appendix A to
Section 172.101, “List of Hazardous Substances and Reportable Quantities.”
To determine if a material is a hazardous substance, you must
use Table I - Appendix A of the HMT.
Now let’s determine if “Ethylene dichloride” is a hazardous
substance. Locate the name “Ethylene dichloride” in the lefthand column of Table
I - Appendix A. Follow across the page to the far right column, entitled
“Reportable Quantity.” Reportable quantities are shown in pounds and kilograms.
The RQ for Ethylene dichloride is 100 pounds or 45.4 kilograms per package. For
this exercise, let’s assume we have 5,500 pounds of “Ethylene dichloride” in a
cargo tank, which is one package. The material is not in a mixture or solution.
Is the “Ethylene dichloride,” as packaged, a hazardous substance?
Answer these two questions. “Is the material listed in Table I -
Appendix A?” Yes, it is listed. “Does the amount of material equal or exceed the
RQ for “Ethylene dichloride?”
Yes, it exceeds the RQ, there are more than 100 pounds in one
package. Therefore, as packaged, the “Ethylene dichloride” is a hazardous
substance for the purpose of transportation.
|