Introduction
The requirement to reflect a Technical Name on shipping papers and packages (in most cases) in addition to the proper shipping name is signified in several ways, based on regulatory publications for the transportation of hazardous materials and dangerous goods.
These include (but are not limited to):
- Capital letter “G”
- Five-pointed star and/or asterisk
- Number 274
This requirement by the regulations comes from the need for more descriptive information, primarily to assist emergency responders in their efforts to provide quick and accurate response when called upon.
Technical names are to be sourced from scientific handbooks, texts or journals. Trade names (e.g. WD40, Ambesol, Clorox, etc.) provide little to no information for emergency responders as they, in most cases, do not reflect the actual chemical or hazardous constituents that must be identified in an emergency situation. Even when the chemical or hazardous constituents are printed somewhere on the package label, in most cases the package is engulfed in the emergency situation leaving responders with the inability to access that information.
Requirements
The regulatory requirement for reflecting technical names depends on which set of regulations that are being used and further delineated by either a Latin character, a symbol or a number.
- The capital letter G in 49 CFR is reflected in the Hazardous Materials Table, Column 1, is the rule which is found in 172.101(b)(4).
- The five pointed Star is found in the IATA DGR Alphabetical List of Dangerous Goods, which is defined in Appendix B, Symbols an abbreviations, B.2.1. The asterisk if found in the ICAO Technical Instructions, Chapter 1, 1.2.7.
- The number 274 is found in the IMDG Code, Volume 2, the Dangerous Goods List, Column 6 Special Provisions, and defined in Chapter 3.3, 3.3.1.
Considerations and Exceptions
There are times when a shipper can use a proper shipping name listed in the regulations as a technical name. Some transportation employees will incorrectly reject this as inappropriate and return the shipment to the shipper which costs time, revenue and customer good will.
For example, a shipper declares the following:
UN 1224, Ketones, liquid, n.o.s. (Acetone), 3
Sometimes, an operator or freight forwarder will reject the technical name of “Acetone” because it is listed as a proper shipping name (UN 1090tone, 3) in the regulations and refuse to validate the accuracy of the declaration or package markings.
What is not realized here is that the regulations themselves could be consider a scientific handbook, text or journal that reflect recognized chemical and biological names. There are even references in the regulations that give examples on how a proper shipping name is to be reflected as a technical name.
Using the IATA Dangerous Goods Regulations, let’s consider the following example:
A shipper takes some UN 1090, Acetone and mixes it with distilled water (non-dangerous goods). This combination of liquids is no longer pure UN 1090, Acetone, 3, II. The flash point has been diluted to 25°C and boiling point is 52.6°C, changing the Packing Group from II to III.
IATA DGR Subsection 4.1 describes the process for “Selecting Proper Shipping Name”. In 4.1.0.2, the regulations list four general types of proper shipping names a shipper may choose from:
- Single entries for well-defined substances,
- General entries for a well-defined group of substances or articles,
- Specific n.o.s. entries covering a group of substances or articles of a particular chemical technical nature, and
- General n.o.s. entries covering a group of substances or articles meeting the criteria of one or more classes or divisions
To properly select the right proper shipping name in this example, the shipper must now refer to IATA Subsection 4.1.3 – Mixtures and Solutions not Listed by Name.
In Subsection 4.1.3.1 – Mixtures and Solutions, there are four exceptions to adding qualifying text “solution” or “mixture” to the proper shipping name. The third bulleted item reads:
“the hazard class or division, subsidiary risk(s), physical state (solid, liquid, gas), or packing group of the mixture or solution differs from that of the substance named in listed Subsection 4.2 – List of Dangerous Goods”
Subsection 4.1.3.1 – Mixtures and Solutions also reads the following:
“For a solution or mixture when the hazard class, the physical state or the packing group is changed in comparison with the listed substance, the appropriate n.o.s. proper shipping name must be assigned, followed by the technical name of the substance in parentheses”
Because mixing UN 1090, Acetone with distilled water changed the flash point and Packing Group from II to III, the shipper must follow these regulations accordingly. Acetone is a Class 3: Flammable liquid and in the Ketone chemical family. As a result, the shipper must declare this as:
UN 1224, Ketones, liquid, n.o.s. (Acetone), 3, III
Conclusion
Whether it’s the shipper, freight forwarder, ground handler or airline, trucking company or vessel operator, it all boils down to proper, in-depth training on the proper use and application of the regulations. When it’s your time to get training, exercise what is taught in any business school by understanding the Latin term of, “Caveat Emptor”, and exercise due diligence as to who is performing your dangerous goods training and how long have they been providing it. There are excellent DG training schools in the market place, just make sure you get one of them.
