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HAZARDOUS
MATERIALS EXPORTS
Exporters
who do business in hazardous
materials or products composed
of or packaged with hazardous
material must be aware of the
steps required to ship these
items. While it is the shipper
who is ultimately responsible
for complying with the
regulations, the exporter can
anticipate the information
needed to deliver their
products success fully. The
diverse nature of hazardous
materials (HAZMATS) requires a
trained person to choose an
authorized solution for each
unique shipping situation.
Often, consulting a
professional shipper is
necessary to ensure that
HAZMAT requirements are met.
The
following is a general
overview on exporting products
that contain, are composed of
or are shipped in a hazardous
material. It is not meant to
be a specific guide to
hazardous material
regulations.
HOW DO I KNOW IF I AM
SHIPPING A HAZARDOUS MATERIAL?
The
Department of Transportation
defines a hazardous material
as a substance capable of
posing an unreasonable risk to
health, safety and property
when transported by rail car,
aircraft, motor vehicle or
vessel in commerce. The DOT
hazardous materials table
lists nine classes of
hazardous materials: 1)
explosives; 2) compressed
gases flammable liquids; 4)
flammable solids; 5) oxidizers
and organic peroxides; 6)
toxic materials; 7)
radioactive material; 8)
corrosive material; and 9)
miscellaneous. If your
shipment is composed of any of
these materials, you are
required to follow a host of
additional steps.
Identifying
a hazardous material is
complicated. Materials may be
known by different names, and
hazards may vary depending on
physical state, what the
material is dissolved in, and
how it is packaged. A close
assessment by one trained in
identifying HAZMATS is
necessary to ensure proper
treatment when transported.
WHO REGULATES HAZARDOUS
MATERIALS EXPORTS?
The U.S.
Department of Transportation's
(DOT), Hazardous Materials
Regulations (HMR 49 CFR Parts
171-180) regulates the
transportation of products
that contain, or are packaged
with hazardous materials. The
regulations apply to transport
by rail car, aircraft, motor
vehicle or vessel shipped
interstate, intrastate or
across national borders.
Several
international organizations
have codes that may be used as
an alternative to the DOT
regulations. The United
Nations issued performance
standards for packaging, which
are used in the international
codes. Most commonly
referenced are the
International Maritime
Organization's Dangerous Goods
Code and the International Air
Transport Association's
Dangerous Goods Regulations
which are based on technical
instructions from the
International Civil Aviation
Organization. International
codes, which are often more
stringent, may be used as an
alternative to DOT regulations
for interstate, intrastate or
international transport.
Restrictions and limitations
on the transport of hazardous
materials are indicated in the
codes as well as options for
packaging.
WHAT ARE
THE MAIN GUIDELINES REGULATING
THE TRANSPORT OF HAZARDOUS
MATERIALS?
HMR 49
mandates training for all
employees handling hazardous
materials. The term
"hazmat employee"
includes anyone who loads,
unloads or handles hazardous
packages, labels hazardous
packages for shipment, fills
out shipping papers or
transports hazardous
materials. These regulations
also apply to consultants who
help shippers identify a
HAZMAT or determine the
acceptability of shipping
containers. Employees
responsible for these tasks
must under go training at
least every three years in
order to comply with HMR
regulations. The training is
meant to heighten employees'
awareness of HAZMATS and to
provide specific instructions
relevant to their job
function. The DOT and many
private organizations provide
specialized HAZMAT training.
Proper
documentation and accurate
labeling must accompany
hazardous materials shipments,
Although no specific form is
mandated, DOT regulations
require there be documentation
with standard information.
Shipping papers are required
to have a description of the
material, including the class
of HAZMAT, quantity being
shipped, the identification
number and the packing group.
Hazmat packages must be marked
and labeled according to the
class of the material and the
quantity being shipped. The
order of the information on
the package marking is also
prescribed.
Packaging
for HAZMATS must also comply
with United Nations
performance standards.
Packaging requirements vary
not only with the risk
associated with the specific
HAZMAT, but the mode of
transportation and volume of
the substance. Each HAZMAT is
put in a packing group
according to the degree of
danger it poses. The packing
groups range from group 1,
indicating the most dangerous
substances, to group III,
indicating minor danger.
The shipper
must also show contingency
information in case of an
emergency including thc phone
number of a person available
24 hours a day during the
transport who is knowledgeable
about the HAZMAT being
shipped. An emergency plan to
guide others in the event of
an accident must also
accompany the shipment.
The
original shipping papers must
contain the following
certification signed by the
shipper "This is to
certify that thc above-named
materials are properly
classified, described,
packaged, marked and labeled,
and are in proper condition
for transportation according
to the applicable regulations
of the Department of
Transportation.' The shipper
must retain all shipping
documents for one year
following the shipment.
HOW DO THE REGULATIONS
OF SHIPPING HAZMATS DIFFER,
DEPENDING UPON THE MORE OF
TRANSPORT?
The mode of
transportation is an important
variable in complying with
HAZMAT regulations. The U.S.
code applies to the transport
of HAZMATS by aircraft, motor
vehicle, vessel and rail, but
also distinguishes the
differences. Standards for the
quantity of material
transported, marking and
labeling, packaging, method of
loading file freight
container, placards
(international signs) on the
freight container and the
certification of the shipper
differs according to
transportation mode.
It is
important for the exporter to
be familiar with HAZMAT
regulations in order to choose
an authorized mode of
transport for the product. The
HMR table distinguishes the
quantity of hazardous material
that may be shipped according
to transportation mode. On a
quantity limitation table,
columns organized by transport
mode indicate the total amount
the carrier may accept. If the
term "forbidden" is
noted in the column, the
material may not be carried by
the described mode.
HOW DO I FIND A CARRIER
WHO WILL HANDLE MY HAZARDOUS
MATERIAL GOODS?
An easy way
to find a qualified HAZMAT
carrier is to contact an
industry association for the
product being shipped. Many
have developed lists of
carriers who are approved to
handle and transport HAZMAT
materials specific to the
industry. Companies who are
prepared to carry HAZMATS
often advertise their ability
to meet these HAZMAT
regulations.
WHERE CAN I FIND
ADDITIONAL INFORMATION ON THE
SHIPMENT OF HAZARDOUS
MATERIALS?
There are
many useful websites that
cover different aspects of
shipping HAZMATS, but no one
website can replace proper
training to insure compliance
with regulations.
The U.S.
Department of Transportation's
Office of Hazardous Materials
Safety's website at http://hazmat.dot.gov/hazhome.htm,
has information on rules and
regulations, international
standards, training
opportunities, emergency
guidelines, exemptions and
enforcement. The Hazardous
Materials Regulation 49 CFR is
online at http://www.myregs.com/dotrspa/. The Office of Hazardous
Materials Standards has a
hotline and a fax on demand
service for answers to
questions on HMR 49. For the
fax on demand service, dial
1-800-467-4922 then press 2.
The
international Air Transport
Association Dangerous Goods
Online information page at http://www.iata.org/
lists endorsed training
schools, a dangerous-goods
primer and frequently asked
questions.
The Bureau
of Transportation Statistics,
National Transportation
Library has a Hazardous
Materials Transportation Guide
online at http://hazmat.dot.gov/pubs/pubs.htm#pubs.
Unz and
Company operates "The
Compliance Observer"
which focuses on hazardous
materials. Please see: http://www.unzco.com/compobserver/index.html.
For more information on any
of these issues, Michigan
firms may contact the
following local resources:
- Your freight forwarder.
- Your freight carrier.
- US Coast Guard – Ocean
Shipments –
313-974-3600.
- Federal Aviation
Administration –
Airborne Shipments –
734/372-3887.
Date
Updated: March 27, 2007
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