Mixed Load, One Page of Paper: Fixing the Basic Description Before the Wheels Turn
You are dispatched to a chemical distributor in Jacksonville, Florida, to pick up a mixed load for Orlando. The dock gives you a single page of shipping paper. It reads:
- "Hydrochloric acid, 8, UN1789, PG II - 8 drums x 55 gal, 4,400 lb"
- "Acetone, UN1090, 3, PG II - 6 drums x 5 gal, 240 lb"
- "Paint related material, UN1263, 3, PG II, 12 boxes, 60 lb, LTD QTY"
The emergency response block says only "CHEMTREC - call collect." The shipper's certification block is unsigned, with a handwritten note reading "signature on file at corporate." The dock supervisor tells you the load is "all non-bulk and under the placard limits, so the paperwork is a formality," then asks you to sign as the shipper's agent so the truck can leave the yard on schedule. You have not yet walked the load.
1. Identify every defect in the three basic descriptions and write the correct entry for each line.
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The basic description must appear in a fixed order: identification number, proper shipping name, hazard class or division, packing group. Additional information such as package count, total quantity, or "LTD QTY" goes before or after that block, never inserted between the four elements.
Line 1 should read: UN1789, Hydrochloric acid, 8, PG II. The class and packing group were reversed. "Hydrochloric acid" is the Column 2 name for UN1789; the synonym "muriatic acid" may follow in parentheses, but a trade name such as "pool acid" could not be substituted. The quantity statement is also inconsistent - eight 55-gallon drums of acid do not weigh 4,400 lb.
Line 2 should read: UN1090, Acetone, 3, PG II. The identification number was moved behind the name.
Line 3 should read: UN1263, Paint related material, 3, PG II, 12 boxes, 60 lb, LTD QTY. Here the basic description is complete, but "LTD QTY" is additional information and does not replace the class or packing group. Confirm the boxes actually carry the limited quantity mark before accepting the notation.
2. Evaluate the emergency response telephone number and the unsigned certification. Can you sign as the shipper's agent to release the load?
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No on both counts.
The emergency response number must be a telephone number, including area code, that is monitored at all times the material is in transportation - including storage incidental to transportation - by a person who has immediate access to the required emergency response information. It must be toll-free or accept collect calls. "CHEMTREC - call collect" fails twice: no number is printed, and nothing on the page establishes that the number is monitored for this shipment. A pager, an answering machine, or a number that forces the caller to look up response information does not qualify.
The certification block is the shipper's representation that the material is properly classified, described, packaged, marked, labeled, and in condition for shipment. An unsigned block with "signature on file" is not a certification, and a carrier driver cannot cure it by signing as the shipper's agent - you are not the shipper and you did not perform the classification. Signing would make you the party certifying facts you cannot verify. The correct action is to refuse to move the load until the shipper issues a corrected, signed document with a working emergency number printed on it.
3. Where must the shipping paper be kept while you drive, and what happens to it if you leave the vehicle or are in a crash?
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The shipping paper must accompany the hazardous material and be kept where it is readily visible to a person entering the driver's compartment, or in a pouch mounted on the driver's door, and it must be within immediate reach while you are restrained by the seat belt. A clipboard tossed on the bunk or a folder in a side box does not satisfy this.
When you leave the vehicle - at a shipper, a scale, a rest stop - the paper goes with you or stays in a place where responders can find it. At the scene of a crash or inspection, you must hand it to a police officer or other authorized official on request. If you are injured and cannot speak, the document pouch in the cab is what tells responders what is on board and what to do about it, which is why it cannot be buried under freight paperwork.
Recordkeeping falls on the shipper, who must retain a copy for two years (three years for hazardous waste). Do not treat the paper as a receipt you can hand off to the receiver and forget.