The University of Chicago
Safety Manual
Occupational Safety and Health Programs

Section 3.28

Hazardous Materials Transportation Program

Please note that this program has a glossary.  The glossary contains the definitions for various terms used in the program.  These terms are highlighted in bold print the first time they appear in the body of the program.

Policy

No employee of the University of Chicago shall offer or accept international, interstate, or intrastate transportation of a hazardous material except in accordance with criteria set forth in this policy and procedure.

Hazardous Material Classifications and Divisions

Under the Hazardous Materials Transportation Program, there are 11 hazard classes (nine numbered and two unnumbered) - classes 1 through 9, plus the classes Combustible Liquids and Other Regulated Materials (ORM).  Note:  Class number does not represent degree of hazard.  Many of these classes are subdivided into divisions, which have numeric decimal values (See Appendix A).

Packaging

Each hazardous material is assigned to one of three packing groups (PG), based on tests for dropping, leakage, etc.  Packing groups I, II and III indicate the degree of danger presented by the material is either great, medium or minor, respectively.  If more than one packing group is indicated for an entry, the packing group for the hazardous material is determined using the criteria for assignment of packing groups specified for each class in 49 Code of Federal Regulations (CFR) 173 Subpart D.  Class 2 and Class 7 materials and ORM-D materials, do not have packing groups. All packing groups are specified in column 5 of the 172.101 Hazardous Materials Table. Contact Safety and Environmental Affairs at 702-9999 for copies of the table.  

Marking/Labeling

General Marking

All markings on the outside of a hazardous material package must be durable, easy to read, in English and unobstructed by anything else on the package.

Marking for Non-Bulk Packaging

The outside of each non-bulk package and any inside containers of hazardous materials must be marked with the following information:

1. Proper shipping name;
2. Identification number (preceded by "UN" or "NA", as appropriate); and
3. Name and address of the consignee or the consignor (the consignee is the person to whom the package is sent.  The consignor is the person who sends the package except when the package is transported by highway only and will not be transferred from one motor carrier to another; or part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to on consignee.

Identification numbers are not required on packages which contain only limited quantities or ORM-D materials.

When a non-bulk package contains inner containers of hazardous liquid materials, the inner containers must be packed with the caps/lids upright.  In addition, it must be legibly marked with package orientation markings on two opposite vertical sides of the package with the arrows pointing in the correct upright direction.  Arrows for purposes other than indicating proper package orientation may not be displayed on a package containing a liquid hazardous material.

For materials poisonous by inhalation, the package shall be marked "Inhalation Hazard" in association with the required labels or placards.  Each non-bulk plastic outer packaging used as a single or composite packaging for materials meeting the definition of 6.1 shall be permanently marked, by embossment or other durable means, with the word "POISON" in letters at least 6.3 millimeters (0.25 inch) in height.  The marking shall be located within 150 millimeters (6 inches) of the closure of the packaging.

If the package contains the reportable quantity of a hazardous substance, the letters "RQ" must be marked in association with the proper shipping name.  Reportable quantity means the quantity specified in column 3 of the appendix to 172.101 Hazardous Materials Table for any material identified in Column 1 of the appendix.

Marking for Bulk Packaging

Bulk packages are required to display the proper shipping name on two opposite sides. The "UN" or "NA" identification number shall be displayed on each side and each end if the packaging has a capacity of 3,785 liters (1,000 gallons), or on two opposing sides if the packaging has a capacity of less than 3,785 liters (1,000 gallons).

For bulk packaging containing materials poisonous by inhalation, the package shall be marked "Inhalation Hazard" on two opposing sides in association with the required labels or placards.

Labeling

Each package containing hazardous materials presented for transportation must be labeled with a hazard label(s) that corresponds to the hazard class of the material it contains. Hazard labels must be placed on the same side of the package as the proper shipping name and "UN" or "NA" identification number markings. These labels must be clearly visible and unobstructed by anything else on the package.

Hazard warning labels must meet strict Department of Transportation (DOT) guidelines regarding size, shape, color and content. Domestic labels will generally have words; however, labels used in international commerce may be wordless. The chart in Appendix C illustrates the proper label that each hazard class or division requires.

If more than one label is indicated on the Hazardous Materials Table, the first one listed is the primary label as determined by the Department of Transportation and any others are subsidiary labels. Primary labels have a class or division number in their lower corner and subsidiary labels do not. The hazard warning labels are diamond-shaped and should measure at least 100 millimeters (3.9 inches) on each side.

Placarding Motor Vehicles

Table 1 below lists those hazard classes which require placards for motor vehicles no matter what amount of material is being hauled. Table 2 includes hazard classes which require placards for motor vehicles carrying hazardous materials, but the amount of material being hauled will determine when placards are required. Transport vehicles containing less than 454 kg (1001 pounds) aggregate gross weight of any of the hazardous materials listed below in Table 2 are not required to be placarded.

 

Table 2: Hazardous Materials

Explosives 1.4 Explosives 1.5 Explosives 1.6 Flammable Gas Non-Flammable Gas Flammable Combustible Flammable Solid Spontaneously Combustible Oxidizer Organic Peroxide Poison Keep Away From Food Corrosives Class 9

Placarding Exceptions

All transport vehicles shall be marked and placarded as specified within this section on each side and each end unless, in an emergency:  the vehicle is escorted by a representative of a state or local government; the carrier has permission from the Department of Transportation; or movement of the transport vehicle is necessary to protect life or property.  Placarding requirements do not apply to infectious substances, hazardous materials classed as ORM-D, hazardous materials authorized to be offered for transportation as limited quantities and identified as such on shipping papers, hazardous materials which are packaged as small quantities, and combustible liquids in non-bulk packaging.

Other considerations to the exceptions are as follows:

1. When more than one division placard is required for Class 1 materials on a transport vehicle, only the placard representing the lowest division number must be displayed;
2. A NON-FLAMMABLE GAS placard is not required on a transport vehicle which contains non-flammable gas if the transport vehicle also contains flammable gas or oxygen and it is placarded with FLAMMABLE GAS or OXYGEN placards as required;
3. OXIDIZER placards are not required for Division 5.1 materials on transport vehicles which also contain Division 1.1 or 1.2 materials and which are placarded with EXPLOSIVES 1.1 or 1.2 placards;
4. An OXIDIZER placard is not required for Division 5.1 materials on a transport vehicle which also contains Division 1.5 explosives and is placarded with EXPLOSIVES 1.5 placards;
5. The EXPLOSIVE 1.4 placard is not required for those Division 1.4 Compatibility Group S (1.4S) materials that are not required to be labeled 1.4S;
6. For domestic transportation of oxygen, compressed or oxygen, refrigerated liquid, the OXYGEN placard may be used in place of a NON-FLAMMABLE GAS placard;
7. Except for a material classed as a combustible liquid that also meets the definition of a Class 9 material, a COMBUSTIBLE placard is not required for a material classed as a combustible liquid when transported in a non-bulk packaging.  For a material in a non-bulk packaging classed as a combustible liquid that also meets the definition of a Class 9 material, the Class 9 placard may be substituted for the COMBUSTIBLE placard;
8. For domestic transportation, a Class 9 placard is not required. A bulk packaging containing a Class 9 material must be marked on each side and each end with the appropriate identification number displayed on an orange panel; or a white-square-on-point display configuration; and
9. For domestic transportation of Division 6.1, Packing Group (PG) III materials, a POISON placard may be used in place of a KEEP AWAY FROM FOOD placard.

Other signs or devices which by color, design, shape or content could be confused with required placards shall not be displayed or affixed on any motor vehicle transporting hazardous materials.

Subsidiary Hazards

A transport vehicle containing two or more categories of materials, requiring different placards specified in Table 2, may be placarded DANGEROUS in place of the separate placarding specified for each of the materials listed in Table 2.

Transport vehicles containing poisonous materials subject to the "Poison-Inhalation Hazard" shipping description or materials which are subject to dangerous when wet subsidiary hazard must be placarded with a POISON or POISON GAS or DANGEROUS WHEN WET placard respectively in addition to any other placard required for that material. Duplication of the POISON or POISON GAS placard is not required.

All placards must be attached to each end and side of the vehicle so that any words or hazard class numbers are horizontal. A minimum of three inches must separate the placard from any other markings or advertising that appears on the vehicle.

It is the responsibility of the shipper to offer the required placards to the carrier when the carrier loads the hazardous materials for transport.

Loading and Unloading

Any tank, barrel, drum, cylinder, or other packaging, not permanently attached to a motor vehicle, which contains any Class 3 (flammable liquid), Class 2 (gases), Class 8 (corrosives), Division 6.1 (poisonous), or Class 7 (radioactive) material must be loaded in such a manner as to secure against movement within the vehicle during transportation.

When hazardous materials are loaded into or unloaded from any motor vehicle, the handbrake must be securely set and all other reasonable precautions will be taken to keep the vehicle from moving during such loading or unloading procedures.

Smoking in or within 25 feet of any motor vehicle while loading or unloading any hazardous material is prohibited.  All fire sources shall be kept away from vehicles hauling any hazardous materials.

The Hazardous Materials Regulations contain Segregation Tables (49 CFR 177.848) which indicate which hazardous materials may not be loaded, transported, or stored together.  Materials which are in packages that require labels, in a compartment within a multi-compartment cargo tank or in a portable tank are subject to the Segregation Tables.  In addition, cyanides or cyanide mixtures may not be loaded or stored with acids.

Containers with valves or other similar fittings shall be loaded so that there is minimum likelihood of any damage to them during transportation. Cylinders containing Class 2 (gases) materials shall be loaded onto a flat floor or platform of a motor vehicle. In order to prevent the overturning of cylinders, all cylinders must be securely lashed in an upright position; loaded into racks securely attached to the motor vehicle; packed in boxes or crates of such dimensions as to prevent their overturning; or loaded in a horizontal position. Cylinders for hydrogen, or cryogenic liquid may only be transported on a motor vehicle which has an open body equipped with a suitable rack or support having means to hold the cylinder upright when subjected to acceleration in any horizontal direction and any motor vehicle carrying such material may not enter a tunnel.

Shipping Papers

All hazardous materials transported in commerce are required to be accompanied by shipping papers.  Shippers may use bills of lading, manifests or way bills as long as these documents contain the required information.  The shipping paper requirements do not apply to materials, other than hazardous wastes or hazardous substances, identified by the letter "A" or "W" in column 1 of the 172.101 - Hazardous Materials Table unless they are intended for transportation by air or water, and materials classed as ORM-D unless they are intended for transportation by air.

The shipping papers must be legible and printed or typed in English.  No unauthorized codes or abbreviations may be used.  A shipping paper may consist of more than one page, if each page is consecutively numbered and the first page bears a notation specifying the total number of pages included in the shipping paper (for example, "Page 1 of 4 pages").

Five items must appear on shipping papers containing hazardous materials:

1. A basic description consisting of four elements in the following sequence:
• Proper shipping name;
• Hazard class or division;
• UN or NA identification number; and
• Packing group number;
2. Total quantity except for empty packaging, cylinders for Class 2 (compressed gases) materials, and bulk packaging, the total quantity (by net or gross mass, capacity, or as otherwise appropriate), including the unit of measurement, of the hazardous material covered by the description (e.g., "800 lbs" or "208 L") must appear on the shipping paper.  For cylinders of Class 2 (compressed gases) materials and bulk packaging, some indication of total quantity must be shown (e.g., "10 cylinders" or "1 cargo tank");
3. Emergency Number:  A 24-hour emergency response telephone number is located on the Material Safety Data Sheet.
4. Certification Statement:  The shipper certifies that the materials listed on the shipping papers have been properly classified, described, packaged, marked and labeled, and are in proper condition for transport according to the regulations established by DOT; and
5. Signature:  The signature of the shipper or his agent signifies that the shipment is in compliance with all relevant regulations.

All shipping papers shall be located so that they are readily available to, and recognizable by, authorities in the event of accident or inspection.  When the driver is at the vehicle's controls, shipping papers shall be within his/her immediate reach or readily visible to a person entering the driver's compartment or in a holder which is mounted to the inside of the door on the driver's side of the vehicle.  When the driver is not at the vehicle's controls, the shipping paper shall be in a holder which is mounted to the inside of the door on the driver's side of the vehicle or on the driver's seat in the vehicle.

When a description of a hazardous material is required to be included on a shipping paper, that description must conform to the following requirements:

1. When a hazardous material and a material not subject to the requirements of this section are described on the same shipping paper, the hazardous material description entries must be entered first;
2. The hazardous material description entries must be entered in a color that clearly contrasts with any description on the shipping paper of a material not subject to the requirements of this section; and
3. Except: A description on a reproduction of a shipping paper may be highlighted, rather than printed, in contrasting color, or must be identified by the entry of an "X" placed before the proper shipping name in a column captioned "HM".

The basic description must be shown in sequence with no additional information interspersed.  For example:  "Gasoline, 3, UN 1203, PG II" (Shipping Name, Hazard Class, Identification Number, Packing Group).

Exceptions include the following:

1. The total quantity of the material covered by one description must appear before or after the description required above.  The type of packaging and destination marks may be entered in any appropriate manner before or after the basic description.  Abbreviations may be used to express units of measurement and types of packaging; and
2. Technical and chemical group names may be entered in parentheses between the proper shipping name and hazard class or following the basic description. An appropriate modifier, such as "contains" or "containing," may be used.  For example: "Flammable liquids, n.o.s. (contains Xylene and Benzene), 3, UN 1993, II." (If the hazardous substance does not appear in the Table and is not a forbidden material, then an appropriate generic or "n.o.s." shipping name shall be selected corresponding to the hazard class and packing group, if any, of the material as determined by 49 CFR 173.2 and 173.2a.  For example, a hazardous substance which is listed in the appendix but not in the Table and which meets the definition of a flammable liquid might be described as "Flammable liquids, n.o.s." or other appropriate shipping name corresponding to the flammable liquid hazard class.

Emergency Response Information

All hazardous material shipments (except those that do not require shipping papers) must have emergency response information on or accompanying the shipping paper.  All emergency response information must legible and in English.  The information on or accompanying the shipping paper must be in the form of the Emergency Response Guidebook, a material safety data sheet, or any other form that provides all the following information:

1. The basic description and technical name of the hazardous material;
2. Immediate hazards to health;
3. Risks of fire or explosion;
4. Immediate precautions to be taken in the event of an accident or incident;
5. Immediate methods for handling fires;
6. Initial methods for handling spills or leaks in the absence of fire; and
7. Preliminary first aid measures.

Hazardous Waste Shipments

A carrier shall not accept a shipment of hazardous waste unless it is accompanied by a properly prepared uniform hazardous waste manifest. Transportation of hazardous waste shall only be conducted by a contractor as provided by Safety and Environmental Affairs.  Disposal of all hazardous waste shall be in conjunction with Section 6.2, Hazardous Materials Management Program.

Training and Information

General Employee Training

• Loads, unloads, or handles hazardous materials;
• Tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packaging as qualified for use in the transportation of hazardous materials;
• Prepares hazardous materials for transportation; or
• Operates a vehicle used to transport hazardous materials.

The training will be conducted within 90 days of employment for those employees whose job functions involve any of the aforementioned hazardous material tasks and once every two years thereafter.  Exception:  Additional training shall be provided within 90 days of any job change involving the use of hazardous materials.

An employee may perform job functions prior to the completion of training provided the employee performs those functions under the supervision of a properly trained and knowledgeable employee.

A comprehensive training program shall include the following:

• General training to provide awareness and familiarization of the requirements of the Hazardous Materials Transportation Program and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standard;
• Function-specific training applicable to the functions the employee performs;
• Safety training pertaining to the following:
• Emergency response information;
• Measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the workplace, including specific measures the employer has implemented to protect employees from exposure; and
• Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials; or
• Any additional department specific training (e.g., Pre-trip safety inspection or the use of vehicle controls and equipment, including the operation of emergency equipment).

• The employee's name;
• The most recent training date;
• A description, copy, or the location of the training materials used to meet the aforementioned training requirements;
• The name and address of the person providing the training;
• Certification that the employee has been trained and tested as required; and
• Results of the learning measurement exercise.

Those employees not demonstrating adequate knowledge, as shown by the learning measurement exercise, will be re-trained until adequate knowledge is shown. Training records will be maintained for the duration of employment and for 90 days thereafter.

Section 3 Index

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Safety and Environmental Affairs
Issued: 01/24/96
Revised: 01/01/08