The Potential Disastrous Consequences of Mislabeling Your Dangerous Goods

Robert Smith | September 29, 2014 | Dangerous Goods/Hazmat
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The Potential Disastrous Consequences of Mislabeling Your Dangerous Goods | Shipping SolutionsWhat’s in a name? When it comes to properly identifying dangerous goods, lots!

There are approximately 3,000 regulated articles and substances listed with an internationally accepted Proper Shipping Name (PSN) and a specific four-digit number associated with each one. With so many to choose from it’s critical that you, the shipper, get it right. If you don’t, the consequences could be catastrophic.

Timing is critical to emergency responders when on-the-spot decisions have to be made. There is no time for second guessing. So from the outset the emergency responders immediately assess the situation by identifying the hazard(s) involved from the placards and labels displayed, and they prepare their response based on those specific hazards.

So where does the PSN figure in all of this? Let’s look at a simple example.

Let’s say a shipper mistakenly identifies your lithium nitride as lithium nitrate. They sound kind of similar, but that’s about all. If your product is involved in a fire, a fire fighter must determine how to extinguish that fire. Lithium nitrate happens to be classified as a Div. 5.1 hazard, which is an oxidizer. This would contribute to a fire and make it burn hotter. If your product is next to a fire and they can’t remove it safely, responders might want to keep that product cool by spraying it with water. But if the product is actually lithium nitride, it is a Div. 4.3 hazard that is dangerous when wet. So by misspelling “ide” with “ate” the shipper just complicated the situation and endangered the lives of the emergency responders.

The average shipper is not a chemist, and identifying and classifying the product being shipped should already be done for them by the manufacturer. All the necessary transportation information can be found in Section 14 of the product`s Safety Data Sheet (SDS). Although this information should be provided, it is still ultimately the shipper who is responsible for properly identifying the product being shipped.

So how do we find the correct PSN? Consulting the domestic regulations, we find the PSNs in column 2 of the hazardous materials table of Subpart B of Part 172 in the Code of Federal Regulations Title 49. They are listed in alphabetical order as they also are in the ICAO Technical Instructions and the IATA DGR for international air transport. For international vessel, the IMDG Code list is actually in numeric order according to the four-digit UN identification number.

The PSN in CFR49 is differentiated by regular type with the associated descriptor text appearing in italics. The DG list in the IATA DGR shows the PSN in bold type with the descriptor in regular type. The IMDG Code shows the PSN in capitals with descriptor text in regular lower case type.

The name in the hazardous materials table or dangerous goods list that most appropriately describes the article or substance must always be used.

The PSN can be singular or plural and printed in capital letters or lower case.

Alternate spellings are allowed if they appear differently in the ICAO-TI or IMDG Code, e.g. Caesium or Cesium.

Domestic transport in the U.S. allows the word poison or poisonous to be used interchangeably with the word toxic.

The materials can be appropriately described by a shipping name that best describes its intended usage, i.e. extracts, flavoring liquid, would be more appropriate than a more generic n.o.s. entry.

N.O.S.? Read on...

There are essentially four types of Proper Shipping Names. From the simple entries that clearly describe the material or article to the complex entries that may involve multiple hazards supplemented with mandatory additional technical names.

The first group of names includes single entries for substances or articles that are well defined such as acetone UN1090; lithium ion batteries, contained in equipment UN3481; and dry ice or carbon dioxide, solid UN1845. The reason UN1845 is listed with alternate names, I was told, is actually due to translation issues with the term dry ice. This is actually an industrial term, and most shippers understand the term. However some languages do not have a translation equivalent and so carbon dioxide, solid is used.

The second group of names covers generic entries for substances or articles that are well defined such as adhesives UN1133; extracts, aromatic, liquid UN1169; and aerosols, flammable UN1950.

In the third group of names, we have specific entries that are not otherwise specified (n.o.s.) elsewhere. These are substances or articles of a particularly unique chemical or technical nature. Examples of these are refrigerant gas n.o.s. UN1223; alcohols n.o.s. UN1987; and self reactive solid, type F UN3230.

Lastly, we have general n.o.s. entries covering a group of substances or articles of a particular chemical or technical nature. Some examples are corrosive liquid n.o.s. UN1759; toxic liquid organic n.o.s. UN2810; and flammable liquid, toxic, corrosive n.o.s. UN3286.

Most n.o.s. entries involve supplementing the PSN with a technical name of the main hazardous ingredient(s). The generic and n.o.s. entries that require supplemental identification are specified differently in the various regulations.

In the CFR49 hazmat table, entries with the letter “G” appearing in the first column identifies proper shipping names for which one or possibly more technical names of the hazardous material must be entered in parentheses, in association with the basic description.

In the ICAO/IATA air regulations, these are identified by a star symbol after the PSN, and in the IMDG dangerous goods list, these are required when Special Provision 274 is indicated for these specific entries.

The technical name shall be a recognized chemical or other name currently used in scientific and technical handbooks, journals and texts and shall be entered in brackets immediately following the Proper Shipping Name. Trade names shall not be used for this purpose. Modifier, such as “contains” or “containing” or other qualifying words such as “mixture” or “solution” and the percentage of the technical constituent may also be used.

A technical name may be necessary when administrating first aid that requires specific details for treating exposure to toxic materials. These would also be pertinent for applying different emergency measures and fire extinguishing media for specific materials, as I demonstrated in the example above. 

As you can see, selecting the Proper Shipping Name requires much more knowledge and precision than first appears. It is a process that is often overlooked and too often taken for granted.