Can someone ship hazardous materials/dangerous goods without using regulatory publications?
This is often a question we ask ourselves when assisting customers. There are so many if’s, and’s, and but’s in the regulations, it’s hard to imagine someone shipping hazardous products without them. The regulations are just large instruction manuals on how to safely ship dangerous materials. We often have customers call and question why their shipment was rejected. After listening to their story, we can usually find the answer right in the regulations. When we tell a customer why their shipment may have been rejected, customers normally see why having a copy of the current regulations is so important. Every company shipping hazardous materials/dangerous goods should have all the regulatory manuals for the modes of transportation which they ship.
“That’s how we have always done it.”
This is something we hear very often, actually.
Just because that’s how you have always done it doesn’t mean it is compliant. The regulations are updated often for a reason – to ensure safety for everyone involved with shipping hazardous materials/dangerous goods. Recently, many of the regulations have been updated to include new UN numbers. The new shipping names and UN numbers will affect the way that companies label and document these products. This could easily become a scenario where “we’ve always done it this way” may lead to penalties or fines.
“These books are too expensive!”
Another reason people tell us that they don’t have copies of the regulations is that the books are too expensive. They are expensive! We totally understand. Often, all we can say is that the cost of a book is going to be less than a fine. It will also save tons of headaches when shipments are rejected with little to no reason. To save costs, it is a wise idea to see what changes are being made to the regulations. If the changes are minor or do not effect any of your products, you can probably wait to purchase a new book until the following edition.
Exemptions and Limited Quantities
There are many exemptions when it comes to limited quantities where the shipper does not have to rely as heavily on the regulations to ship compliantly. However having a copy of the regulations on hand can be used to determine the requirements for these exemptions. Recently there have been some changes to limited quantities regulations. For instance, a new label, black and white square on point label, is to be added to the packages and even varies depending on the mode of transportation. Previously, there was no label requirement for limited quantities. With these types of changes, a copy of the regulation will always be needed no matter if shipping limited quantities or bulk dangerous goods.
Authorities don’t mean to trick people when writing all these rules, even though it can be hard to decipher what they really mean. There are plenty of resources that will help break the code of regulations. ICC has a reputation for delivering excellent regulatory support; if you need help you can contact us online or over the phone in the US at (888) 442-9628 or in Canada at (888) 977-4834.
Remember, in the hazardous materials/dangerous goods business, there is no such thing as a stupid question.