Regulatory Helpdesk: March 26

Proper shipping name, 500 kg exemption, MANCOMM symbol, and a TDG error

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Proper Shipping Name (49 CFR)

Q. The customer wanted to know if they can print the product name in section 1 of the SDS next to the UN number on a hazard class label instead of the proper shipping name.

A. No. The proper shipping name on the outside of the box is a requirement per 49 CFR §172.301 (a) (1) and must be marked along with the UN number in a non-bulk packaging.

500 kg Exemption (TDG)

Q. Can I apply the 500 kg exemption when I have a mixed load where part of the load is excluded from using a DANGER placard under the 1000 kg Class restriction in TDGR §4.16 but the remainder is less than 500 kg gross? An example would be a consignment offered that included 1200 kg of Class 3, 100 kg of Class 8 and 300 kg of Class 9 (no ERAP required for either)?

A. In the DANGER placard scenario in 4.16, the Class 3 is restricted from using the DANGER placard specifically, based solely on quantity. Regular placarding requirements apply to the load based on the guidance text in the introduction to 4.16.

Although there is provision in the TDGR §4.16.1 – “500 kg Gross Mass Exemption” explanatory text (and a similar “FAQ”) to subtract mandatory placarded (restricted class) goods from the total and applying the exemption to what’s left, this provision does not apply to the situation described above.

In §4.16.1 the part of a load subject to restriction from the exemption is based on the hazard. The restricted hazard classes may be subtracted and the exemption applied to the remainder.

§4.16 does not indicate that a portion of non-restricted hazard class is excluded from the gross load weight.

Thus, in the above example, Class 3 placards would be required; along with either Class 8 and Class 9 or DANGER.


Q. I have a copy of the MANCOMM 49 CFR purchased from ICC. At the bottom of the hazardous materials table in §172.101 there is a symbol with 4 diamonds ❖. What does it mean?

A. That symbol is an indication for information that changed or was updated in the last year.

Error spotted in the TDG Regulations

Note the following error found in the TDG Regulations. Transport Canada states that it will be corrected in next published amendment.

TDG English version

§1.3 (2) (d)

(iv) for solutions and mixtures, followed by the word “SOLUTION” or “MIXTURE”, as appropriate, and may include the concentration of the solution or mixture; and

Version française TMD

(iv) de les faire précéder des mots « SOLUTION » ou « MÉLANGE », selon le cas, et la concentration de la solution ou du mélange peut être incluse;

**English version says that for solutions and mixtures, the shipping names can be followed by the word SOLUTION or MIXTURE

The French version says that for solutions and mixtures, the shipping names can be preceded with the word SOLUTION ou MÉLANGE

Karrie Ishmael

Karrie Ishmael

Karrie started with the company in 1988 and has worked in a variety of capacities including customer service, sales, management, and marketing. In her current role as Regulatory Manager, she manages and supports ICC's efforts in supplying value-added services including training and SDS services to our clients. She is knowledgeable in a variety of regulations. She actively participates in a multitude of associations including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.