how to describe a dot special permit or exemption on a hazardous material shipping paper

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THE ADDITIONAL DESCRIPTION ON THE HAZMAT SHIPPING PAPER One presentation in a series that briefly explains the responsibility of the Shipper of a hazardous material to provide an “additional description” on the shipping paper if applicable. 49 CFR 172.203(a) @DanielsTraining 1 This presentation: 49 CFR 172.203(a): Special Permit (aka: Exemptions)

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DESCRIPTION

The Hazardous Materials Regulations (HMR) of the PHMSA/USDOT require a Shipper of a hazardous material (HazMat) to describe the hazardous material on a shipping paper pursuant to 49 CFR 172, Subpart C. The Shipper must then provide a certified copy of the shipping paper to the Carrier who is responsible to maintain it throughout the hazardous material’s time in transportation. It is the responsibility of the Shipper to provide an additional description on the shipping paper if the hazardous material it offers for transportation is subject to the regulations of 49 CFR 172.203 Additional Descriptions. It is your responsibility as a Shipper of HazMat to comply with these regulations and to provide the required Function Specific training to your HazMat Employees.

TRANSCRIPT

Page 1: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 1

THE ADDITIONAL DESCRIPTION ON THE HAZMAT SHIPPING PAPEROne presentation in a series that briefly explains the responsibility of the Shipper of a hazardous material to provide an “additional description” on the shipping paper if applicable.

49 CFR 172.203(a)

This presentation: 49 CFR 172.203(a):Special Permit (aka: Exemptions)

Page 2: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 2

PRESENTED BY:

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

A different kind of training.

49 CFR 172.203(a)

Page 3: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 3

49 CFR 172.203 – Additional Description

• The Shipper of a hazardous material (HazMat) is required to describe it on a shipping paper.

• The regulations detailing the hazardous material description are found at 49 CFR 172, Subpart C.

• An additional description of the HazMat may be required depending on the hazardous material and the mode of transportation.

• The shipping paper must accompany the hazardous material shipment until it reaches its final destination.

49 CFR 172.203(a)

Page 4: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

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Describing a Special Permit or Exemption on the Shipping Paper

If…• A Special Permit or Exemption is required for the transportation of your hazardous material.

Then…• It is necessary to indicate the Special Permit/Exemption number on the shipping paper.

49 CFR 172.203(a)

“Except as provided at §173.23” …more on this later

Page 5: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

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Describing a Special Permit or Exemption on the Shipping Paper• Number must be:

• Near the HazMat description to which it applies.• “…clearly associated with…”

And…• Preceded by the notation:

• “DOT-SP” if issued on or after 10.01.07.• “DOT-E” or “DOT-SP” if issued before 10.01.07.

49 CFR 172.203(a)

Exact location on shipping paper not specified

Page 6: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 6

“Except as Provided at §173.23…”

• 49 CFR 173.23 – Previously Authorized Packaging identifies specific situations where a permanently marked packaging or shipping paper may continue in use as long as specified conditions are met.

Example:• “An exemption packaging or shipping paper that is permanently marked “DOT-E” prior to October 1, 2007, may continue in use as long as the exemption or special permit remains valid, unless otherwise specified in the exemption or special permit.”

49 CFR 172.203(a)

Page 7: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 7

What Does it Look Like?

49 CFR 172.203(a)

Page 8: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 8

More to Consider(1)…

• Prior to October 1, 2007 a Special Permit was identified in the HMR as an Exemption.

• A Special Permit or Exemption, if used in compliance with the regulations, allows a Shipper or Carrier to transport a HazMat in a manner not allowed by the HMR.

• The use of a Special Permit by a Shipper or Carrier will require HazMat Employee training that addresses the requirements of the Special Permit.

49 CFR 172.203(a)

Page 9: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

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More to Consider(2)…

• A copy of the Special Permit must be in the possession of the Carrier and the Shipper.

• More information:• Special Permit FAQs.• Search for a Special Permit.• PHMSA’s Special Permit webpage.

49 CFR 172.203(a)

Page 10: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

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49 CFR 172.203(a) Verbatim:

(a) Special permits. Except as provided in §173.23 of this subchapter, each shipping paper issued in connection with a shipment made under a special permit must bear the notation “DOT–SP” followed by the special permit number assigned and located so that the notation is clearly associated with the description to which the special permit applies.

49 CFR 172.203(a)

More…

Page 11: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

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49 CFR 172.203(a) Verbatim:

Each shipping paper issued in connection with a shipment made under an exemption or special permit issued prior to October 1, 2007, may bear the notation “DOT–E” followed by the number assigned and so located that the notation is clearly associated with the description to which it applies.

49 CFR 172.203(a)

End.

Page 12: How to Describe a DOT Special Permit or Exemption on a Hazardous Material Shipping Paper

@DanielsTraining 12

Got Questions About RCRA or HazMat Transportation?

I provide both:

RCRA Training for Hazardous Waste Personnel

And…

HazMat Employee Training

Seminar, Webinar, or Onsite

Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com

49 CFR 172.203(a)

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