1.2 Shipping Paper Requirements and Description Order

Why This Topic Matters on the Exam

Shipping papers are the lifeblood of hazardous materials transportation. In the event of a crash, chemical spill, or fire, emergency responders (such as firefighters and police officers) rely on these papers to identify the hazards and take immediate, correct action. If a driver is unconscious or incapacitated, first responders will look for the shipping papers to determine the risks. Therefore, shipping papers must be filled out with absolute precision. Even a minor error in the description order or formatting can lead to disastrous delays during an incident, and is one of the most heavily penalized violations during roadside inspections conducted by the Texas Department of Public Safety (DPS). The HME exam tests your ability to identify the correct sequence of the hazardous materials description and the required additional entries on the shipping paper.

The Basic Description: ISHP Order

The most important rule to memorize for the exam is the mandatory sequence of the basic description. The DOT requires that the basic description of any hazardous material be written in a specific, non-negotiable order. There are no exceptions to this sequence, and writing it in any other order is a federal violation. You must memorize the acronym ISHP, which represents the following four elements in order:

1. Identification Number (I): This is a four-digit code preceded by 'UN' (United Nations) or 'NA' (North American). It identifies the specific chemical substance or group of substances (e.g., UN1203 for gasoline).
2. Proper Shipping Name (S): This is the official name of the material as designated by the DOT in the Hazardous Materials Table (e.g., Gasoline).
3. Hazard Class or Division (H): This is the numerical category that represents the primary hazard type (e.g., 3 for flammable liquids). If the material has a subsidiary hazard class, that class must be listed in parentheses immediately following the primary class.
4. Packing Group (P): This indicates the degree of danger presented by the material, represented by Roman numerals (e.g., PG II for medium danger). The packing groups are:
   • PG I: Great danger
   • PG II: Medium danger
   • PG III: Minor danger (Note: Class 2 gases, Class 7 radioactive materials, and Division 6.2 infectious substances do not have packing groups.)

An example of a correct basic description is: UN1203, Gasoline, 3, PG II

Additional Shipping Paper Entries

In addition to the basic description, the shipping paper must contain other critical pieces of information. These elements provide context on the volume and quantity of the material being transported, and how to handle it:

• Total Quantity and Unit of Measure: The shipping paper must show the total quantity of hazmat in the shipment. This is expressed in weight, volume, or count (e.g., '1000 lbs', '500 gallons', or '10 cylinders').
• Number and Type of Packages: The paper must indicate the number and description of the physical packages holding the materials (e.g., '5 drums', '2 cargo tanks').
• Emergency Response Telephone Number: This is a 24-hour, monitored phone number. The number must be staffed by someone who is knowledgeable about the hazardous material being shipped and has comprehensive emergency response info, or someone who has immediate access to a person who does. If the shipper uses a third-party provider (like CHEMTREC), the shipper's registration number or name must be listed alongside the phone number.
• Shipper's Certification: The shipper must sign a legal statement certifying that the shipment has been prepared in accordance with DOT regulations. The most common certification statement is: 'This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.'

Special Markings and the Hazard Column

When a shipping paper lists both hazardous and non-hazardous materials, the hazardous materials must be easily distinguishable. The regulations provide three ways to do this on the document:

1. The HM Column: The shipper can include a column labeled 'HM' (Hazardous Materials). A checkmark or 'X' in this column indicates that the item on that line is hazardous.
2. Distinctive Print Color: The hazardous materials can be printed in a contrasting color, such as red, to make them stand out from non-hazardous items.
3. Listing Order: The hazardous materials can be listed first on the shipping paper, followed by non-hazardous items.

The "RQ" Marking (Reportable Quantity)

If the shipment contains a Reportable Quantity (RQ) of a hazardous substance (a quantity that, if spilled, must be reported to the National Response Center under EPA rules), the letters 'RQ' must be written on the shipping paper. The 'RQ' can be placed in the HM column, before the identification number, or before the proper shipping name. This alerts the driver and emergency responders that a spill of this package is subject to immediate federal reporting requirements.

Toxic-Inhalation Hazards

If a material is hazardous because of its toxicity when inhaled, the shipping paper must contain the words 'Toxic-Inhalation Hazard' or 'Inhalation Hazard', along with the specific hazard zone (e.g., 'Zone A', 'Zone B'). This information is vital because it changes the routing requirements and the emergency response protocol (e.g., requiring respirators and immediate evacuation zones).

Scenarios and Traps for Drivers

The "Formatting Overload" Trap: A shipper hands you a manifest that lists: Gasoline, UN1203, Class 3, PG II. When you look at it, you see that every bit of information is technically correct: gasoline is UN1203, it is class 3, and it is packing group II. However, the sequence is wrong because the shipping name is listed before the identification number. In a real-world scenario, if you accept this paperwork, you are committing a violation. Troopers at inspection stations look at this exact sequence. If it does not follow the ISHP order, the vehicle can be delayed or placed out of service. You must ask the shipper to correct the order before signing the receipt.

The "Emergency Number" Trap: You are checking your shipping papers at a terminal in Dallas. The emergency response phone number is listed as the shipper's main office line. However, it is a Saturday night, and the shipper's office is closed. If a trooper or an emergency responder attempts to call that number and gets an automated voicemail, it is a major regulatory violation. The emergency number must be monitored 24 hours a day, 7 days a week, while the shipment is in transit. As a driver, you must verify that the emergency number is active and valid before embarking on your route.