Hazmat Survival Tips: Using Shipping Papers during Highway Transportation Incidents

Since there may be circumstances when both “regulated’ and “non-regulated” materials are included on the same document, federal transportation regulations require that the information for hazardous materials be listed in such a way as to get the reader’s attention. This can be accomplished in several ways including:

Once first responders have gathered shipping papers for materials believed to be still loaded on a vehicle, they must then determine if any of these documents contain entries for “hazardous materials.” As stated previously, these entries may be listed first, the entries may be marked with an “X,” or the entries may be highlighted. In addition, shipping papers that contain hazardous material entries may be “flagged” by the shipper or carrier with an attached tag. But remember, these rules apply only to a regulated hazardous material and there may be other items loaded that could still pose potential problems to first responders. 

When reading shipping papers, first responders should pay attention to the Packing Group. According to 49 CFR172.101 (f), “Packing Groups I, II, and III indicate whether the degree of danger presented by the material is either great, medium, or minor, respectively.” Therefore, while not all hazardous material entries will include reference to a packing group, the benefit to first responders when available is that without any additional information about a hazardous material other than its Packing Group, first responders know at least that a material listed as Packing Group I is probably some bad stuff!      

Shipping papers should also provide information regarding the type and number of containers. This can be helpful in attempting to assess the magnitude of the incident and how you can expect the containers to react. Remember that hazardous materials become a problem only when released from their containers or when the containers are stressed with a potential for a release. 

Probably some of the most important information contained on shipping papers is an “emergency response telephone number.” This number must be provided by the person who offers a regulated hazardous material for shipment (the shipper). According to 49 CFR 172.604(a), this telephone number must be, “Monitored at all times the hazardous material is in transportation, including storage incidental to transportation,” and the number must be for “a person who is knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge and information.”   

Some first responders also believe that if there is more than one shipping paper, then the position of the papers if stacked together indicates the relative position of the shipment on the vehicle. For example, shipping papers on top of a stack would be for shipments towards the rear of the truck and papers on the bottom of the stack are for those near the nose of the vehicle. Although this may apply in some circumstances, there is no way to assure first responders that this will always be the case. Instead, a driver may have freight loaded down one side of the vehicle and the potential is for the last stop to be on the back of the vehicle. This may occur if this shipment is on a pallet that needs to be near the rear of the trailer so that a forklift can reach it from the ground.

In some instances, first responders can encounter a trailer that has been disconnected from its tractor (usually referred to as a “dropped” trailer) at locations other than its origin or destination. This can occur at a truck stop, repair shop, or even on the side of a highway, and is often the result of a driver who is at home or at a local motel during a rest break. If the trailer contains certain types of regulated hazardous materials, the transport vehicle may sometimes be marked with the telephone number of the motor carrier or the shipping papers may be readily available on the vehicle.             

Steven M. De Lisi recently retired from the fire service following a 27-year career that included serving as the deputy chief for the Virginia Air Guard Fire Rescue and a division chief for the Virginia Department of Fire Programs (VDFP). De Lisi is a hazardous materials specialist and as an adjunct instructor for VDFP, he continues to conduct hazardous materials, and awareness and operations-level training for fire suppression and EMS personnel. De Lisi began his career in hazardous materials response in 1982 as a member of the hazmat team with the Newport News (VA) Fire Department. Since then, he has also served as a hazardous materials officer for the Virginia Department of Emergency Management; in that capacity, he provided on-scene assistance to first responders dealing with hazardous materials incidents in a region that included more than 20 local jurisdictions. De Lisi holds a master’s degree in public safety leadership and is the author of the textbook Hazardous Material Incidents: Surviving the Initial Response, (Fire Engineering).