The Friday-Afternoon Shipping Paper
Renee is a hazmat driver for a Kentucky carrier. At 5:15 p.m. Friday she arrives at a Frankfort shipper to pick up 18 non-bulk drums of UN1263, Paint (Class 3, PG II), and 6 drums of UN1830, Sulfuric acid (Class 8, PG II). The shipper hands her a shipping paper that lists “Paint, 3, UN1263, PG II, 18 drums” and “Sulfuric acid, 8, UN1830, PG II, 6 drums.” It shows the consignee in Cincinnati and the total net weight, but the emergency response telephone number is the shipper’s office line, which closes at 6 p.m., and the shipper’s after-hours voicemail says to call the sales manager’s cell. The paper has no ERG guide numbers. The shipper’s clerk says, “The guide number isn’t required, and our sales manager always answers.” Renee also notices the paper does not say “Waste” on one drum that is marked with a hazardous waste manifest number. The shipper wants the truck to leave before the dock closes.
1. Is the shipping paper acceptable for highway transport? Identify each deficiency and whether the ERG guide number is required.
Read the worked answer
The paper is not acceptable as offered. The basic description order is close, but the emergency response telephone number must be monitored at all times while the material is in transport, including nights and weekends. A shipper office line that closes at 6 p.m. and rolls to a sales manager’s cell is not automatically compliant; the number must be answered by someone capable of providing emergency response information, and the shipper must ensure it is monitored. The ERG guide number is not a required field on the shipping paper, so its absence alone is not a defect, but the 24-hour contact is. If the drum is hazardous waste, the shipping name must begin with WASTE and the shipment must move under the hazardous waste manifest; the paper cannot ignore that drum. The shipper also must certify the paper. Renee should not sign until these are corrected.
2. What should Renee do before signing and leaving?
Read the worked answer
She should tell the shipper the paper cannot be accepted until the emergency contact is a monitored 24-hour number, either the shipper’s own monitored line or a contract emergency response service. She should ask the shipper to correct the waste description and manifest reference on the one drum, and to recheck that every package description and quantity matches the load. She should verify labels and placards before loading. If the shipper cannot correct the paper, she should contact dispatch and refuse the load; signing or leaving with a defective paper puts her and the carrier at risk. A cell phone can be acceptable only if the shipper demonstrates it is monitored at all times and the person can provide the emergency response information.
3. If the sales manager’s cell phone is the only after-hours number, can it satisfy the emergency response requirement?
Read the worked answer
If the cell is truly answered 24 hours a day by a person who can provide emergency response information for the material, a cell number can satisfy the requirement; the rule does not require a landline or a specific service. But Renee should not assume that from a voicemail greeting. The shipper must be able to show the number is monitored at all times during transport. If the number goes unanswered or the person cannot provide the information, it is not compliant. The ERG guide number is helpful but not a substitute for the 24-hour contact. She should resolve this before departure, not after a leak.