The Drum With No Label and the Phone That Goes Home at Five
You are at a Grand Rapids paint and coatings distributor to pick up 24 fifty-five-gallon drums. The shipping paper the clerk hands you reads, in this exact order: 'Paint, 3, UN1263, PG II, 24 drums, 1,200 lb.' Walking the pallets, you see every drum carries a FLAMMABLE LIQUID label, but two drums also carry a CORROSIVE label. One drum near the door has no hazard label at all; the clerk says it 'fell off in the warehouse and it is the same stuff.' The emergency response telephone number on the paper is the clerk's desk extension, and the office closes at 17:00; you will be driving until 02:00. The clerk says he will email a corrected paper tomorrow and that you should 'sign and go, since it is all Class 3 anyway.' Your appointment in Traverse City is 08:00 and the customer has a dock deadline.
1. Rewrite the basic description correctly and explain what determines its order and content.
Read the worked answer
Correct entry: UN1263, Paint, 3, PG II, 24 drums, 1,200 lb - with a subsidiary hazard added in parentheses if one is genuinely present, e.g. UN1263, Paint, 3 (8), PG II.
The basic description has a fixed sequence:
- UN identification number first (UN1263), not buried after the name.
- Proper shipping name exactly as listed in the hazardous materials table.
- Hazard class or division (3).
- Subsidiary hazard, if any, in parentheses immediately after the primary class.
- Packing group (PG II).
Then the total quantity, number and type of packages, and the emergency response telephone number.
Why the order matters: responders and inspectors read the paper under stress, left to right. A description that starts with the product name forces them to hunt for the ID number they need to open the orange guidebook. The sequence exists so the first four characters on the page are the four characters they will look up.
The real issue on this dock is not the order - it is the conflict. Two drums say the material carries a corrosive subsidiary hazard; the paper says it does not. Either the labels are wrong or the paper is incomplete. You cannot resolve that from the loading dock, and you are not authorized to pick one.
2. Which of the 24 drums may you load, and what is your basis for deciding?
Read the worked answer
None of the three problem drums until the shipper reconciles them - and you should not break the pallet to sort them out.
- The unlabeled drum cannot be transported. Hazard labels are required on the package, and a package missing a required label has not been properly offered. 'It fell off' is a warehouse problem, not a transportation exemption. A responder who finds that drum in a wreck has no idea what is leaking.
- The two over-labeled drums are a documentation conflict. Either the shipper determined the material has a corrosive subsidiary hazard (in which case the paper must read
3 (8)and the entry is wrong), or the labels were applied in error (in which case the shipper must remove them - you may not). - The driver has no authority to relabel, reclassify, or amend a shipping paper. Those are the offeror's duties. Peeling a label off or writing '(8)' on the paper yourself converts a shipper error into your violation.
What to do: ask the shipper to either replace the missing label or pull that drum, and to state in writing whether the two drums carry a subsidiary corrosive hazard. Then match the corrected paper against the labels drum by drum before you sign.
Exam instinct: a shipping paper that does not match the packages is a stop-work condition, not a note for later. The corrected paper 'emailed tomorrow' does not travel with the load, and the paper must accompany the shipment.
3. Is the emergency response telephone number on the paper acceptable? What must be true before you sign?
Read the worked answer
No. A desk extension that is unanswered after 17:00 fails the requirement.
The emergency response telephone number on a shipping paper must be monitored at all times while the material is in transportation, including during storage incidental to movement, and it must reach a person who either knows the material and its hazards or has immediate access to someone who does. A number that rings an empty office for the nine hours you are actually driving is the exact failure the rule targets: the call comes at 23:40, not at 14:00.
Before signing, you need a number that satisfies three tests:
- Answered 24/7 for the whole trip, including weekends and holidays.
- Connected to a knowledgeable party - the shipper, a contracted emergency response service, or a carrier-registered service - able to give responders the product identity, hazards, and handling advice.
- Printed on the shipping paper you carry, not on a sticky note or in an email.
If the shipper names a commercial response service, that is fine - but confirm the service has actually been engaged for this shipment and the number is live, not a brochure number.
Bottom line: the deadline does not create an exemption. A load that departs with a dead emergency number is noncompliant from the moment it leaves the gate, and the driver is the last person who can catch it. Escalate to your dispatcher and get a compliant paper before the wheels turn.