Do you know what to do when you need to ship hazardous material (hazmat) samples? The Department of Transportation (DOT) requires hazmat shippers to classify materials, appropriately describe and label them and use the right packaging [49 CFR 173.22(a)].
But what if you don’t know exactly what it is you’re dealing with? There are many times when this could be the case, including when:
- You need to ship a sample of some unknown or mostly unknown material to a lab for analysis
- You need the lab results to help you to classify the material
- The sample is a hazardous waste from a spill and you don’t have technical data available
Don’t worry. The DOT has these special circumstances covered under Hazardous Material Regulations, which describe how a shipper may classify and ship a hazardous waste or an unknown hazardous material to a lab for analysis [49 CFR 172.101(c)(11)].
This regulation applies to two broad categories of materials:
- Materials subject to EPA hazardous waste regulations at 40 CFR 262
- Material samples of uncertain hazard class that can only be determined by testing
The regulation does not apply to the following materials:
- A material or package forbidden for transportation at 49 CFR 173.21
- A forbidden Class 1 Explosive at 49 CFR 173.54
- Samples of Class 1 Explosives transported for examination according to 49 CFR 173.56(d)
- Transportation of unapproved Class 1 Explosives per 49 CFR 173.56(e)
- New self-reactive materials, formulations, and samples identified at 49 CFR 173.224(c)
- New Division 5.2 Organic Peroxides, formulations and samples identified at 49 CFR 173.225(b)
Applicable hazardous materials may be classified by the shipper and assigned a tentative shipping description, including the following from the Hazardous Materials Table at 49 CFR 172.101:
- Identification number from column 4
- Proper shipping name from column 2
- Hazard class from column 3
- Subsidiary hazard class (if applicable) from column 6
- Packing group (if applicable) from column 3
The shipper’s tentative determination must be made according to each of the following:
- The requirements of the DOT Hazardous Material Regulations
- The precedence of hazard table at 49 CFR 173.2a for determining the primary and subsidiary hazard classes (if applicable)
- The shipper’s knowledge of the material
Selecting Packaging and the Hazard Communication Methods
When samples are being transported, the shipper may use the exception for samples found in 49 CFR 172.101(c)(11). But, they must use a DOT specification package that is properly labeled and marked, as well as meet the other applicable rules for transporting a hazardous material.
This is made clearer by a DOT Letter of Interpretation which reads in part “In addition, the sample (tentatively assigned to Division 6.2) must be transported in accordance with all HMR requirements applicable to the transportation of Division 6.2 materials” (LOI 04-0270).
But if you intend to ship a sample under this exception, you’re not done. That’s because a shipper of a sample – not a hazardous waste – must also comply with the following:
- Include the word “Sample” as part of the proper shipping name or near the basic description of the hazardous material on the shipping paper. This is not required if “Sample” is already part of the proper shipping name, of which there are only two:
- UN3169, Gas sample, non-pressurized, toxic, n.o.s., not refrigerated liquid
- UN0190, Samples, explosives, other than initiating explosives
- The technical name for the constituents of a generic shipping name, if chosen as the tentative shipping description, are not required. A generic shipping name displays a ‘G’ in column 1 of the Hazardous Materials Table at 49 CFR 172.101.
- A sample must be transported in a combination packaging (i.e. a packaging with at least one inner receptacle packaged in an outer packaging). The net mass of the hazmat sample in the packaging may not exceed 2.5 kg (5.5 lbs) per package. This combination packaging must be authorized for the tentative shipping description chosen and manufactured to meet DOT specifications that apply to the tentative packing group (if applicable).
This exception to full regulation allows a shipper to transport a hazardous waste or an unknown hazardous material if it is being sent to a lab for analysis. If you use this exception, take care to ensure you comply with its conditions and don’t exceed its limits. Also, be sure that anyone involved in a hazardous material’s classification, packaging or shipping (even a sample with a tentative shipping description) receives hazmat training required by the DOT.