Shipping Paper Errors on an Overnight Peoria Load
At a warehouse in Peoria, Illinois, you are tendered a mixed load with this shipping paper: 'Paint, UN1263, 3, PG II, 24 drums, 3,600 lb'; 'Hydrochloric acid, 8, UN1789, PG II, 6 drums, 2,400 lb'; 'Lithium ion batteries, UN3480, 9, 3 boxes, 90 lb.' Emergency contact: 'Peoria Chemical, (309) 555-0177, 8:00 a.m. to 5:00 p.m., Monday through Friday.' The shipper says the paper is 'close enough' and that the 24-hour number is the same office. The load will travel overnight to Chicago. You also see that the hydrochloric acid drums have CORROSIVE labels but the paint drums have no labels; the shipper says labels fell off. The vehicle is already placarded FLAMMABLE and CORROSIVE.
1. Identify the errors in the basic descriptions and give corrected entries for all three lines.
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The basic description sequence is wrong on all three lines. The required order is UN number, proper shipping name, hazard class/division, subsidiary hazard if any, and packing group. Corrected: 'UN1263, Paint, 3, PG II, 24 drums, 3,600 lb'; 'UN1789, Hydrochloric acid, 8, PG II, 6 drums, 2,400 lb'; 'UN3480, Lithium ion batteries, 9, 3 boxes, 90 lb.' The word 'corrosive' is not needed in the basic description because Class 8 already communicates corrosivity; additional descriptive text may appear elsewhere but must not disrupt the required sequence. Lithium ion batteries are Class 9 and do not have a packing group in this entry. The paper must also show the total quantity and package count. Because responders will use the paper, 'close enough' is not acceptable.
2. What is wrong with the emergency response telephone number, and what must the shipper do?
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The emergency contact is defective. 49 CFR 172.604 requires the emergency response telephone number to be monitored at all times while the hazardous material is in transportation, including storage incidental to movement. An office number answered 8:00 to 5:00 Monday through Friday does not satisfy that requirement for an overnight run to Chicago. The shipper must provide a number that is answered 24 hours by a person who knows the material and has access to response information, or the shipment cannot be accepted. A voicemail or answering service is not enough unless it can immediately reach someone who can provide the required information. If the shipper cannot supply that number, refuse the load and document the refusal.
3. Can you accept the load if the shipper corrects the paper but not the missing paint labels?
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No. Fixing the paper does not cure missing package labels. Labels communicate the hazard at the package level, while placards communicate it at the vehicle level; one does not substitute for the other. The driver's check is not a substitute for the shipper's duty, but accepting unlabeled packages puts the driver and responders at risk and violates the communication rules. The practical answer is to hold the load, ask the shipper to apply correct FLAMMABLE LIQUID labels and provide a compliant 24-hour number, and verify the placards on the vehicle match the classes loaded. If the shipper cannot correct the labels, refuse the shipment and document what was wrong.