The BOL That Isn't Ready and the Office-Hours Emergency Number
At 04:40 you report to a chemical distributor to pick up a prepaid load for a customer 260 miles away. The shipping clerk hands you a one-page bill of lading. The description reads: 'Hydrochloric Acid Solution, Corrosive, 12 drums, 6,600 lb,' and two lines lower, 'UN1789, Class 8, PG II.' The emergency response telephone number is the distributor's office line, staffed 08:00 to 17:00 Monday through Friday; there is no 24-hour number and no contract number. The clerk says an ERG is already in the cab and that this satisfies the emergency response requirement. On the dock you count twelve 55-gallon drums; the last one is slightly bulged and has dried white crust around the bung. Dispatch radios that the receiver closes at noon and tells you to 'sign and roll, we'll email corrected paperwork to the receiver before you get there.' The trailer is empty, the dock is busy, and the outside temperature is 94 degrees.
1. Evaluate the shipping paper. What is missing, out of order, or noncompliant, and may you sign for and move this load?
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Start with the basic description. The hazard class, UN number and packing group must appear with the proper shipping name in the required sequence (proper shipping name, hazard class, UN identification number, packing group), either on the same line as the shipping name or in designated columns keyed to it. Here the UN number and packing group sit two lines below the name, and 'Corrosive' is written as a word rather than the class number '8.' A shipper-prepared, legible paper containing all required information is a precondition to your accepting the shipment; signing the bill is accepting it, so you cannot sign as presented. Note also that '12 drums, 6,600 lb' is a total quantity with unit of measure, which is acceptable.
The bigger defect is the emergency response telephone number. The requirement is a number that is monitored at all times the material is in transportation, including storage incidental to movement, and that connects to someone who either has knowledge of the material or has immediate access to a person who does. A weekday office line fails that test, and if a contract number is used it must be shown with the number. The ERG satisfies the separate emergency response information requirement only if it is the current edition and covers the material; it does not substitute for a monitored phone number. Two different requirements, one document, and the clerk has conflated them.
2. Dispatch insists the load must move. What specific, workable fix satisfies the rule before you leave the dock, and what do you do if the shipper refuses?
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The fix has to be made by the shipper, not by you. A carrier or driver annotating the shipping paper does not cure a shipper defect; the paper is the shipper's certification. Ask for two changes: a corrected description in the required sequence with the class number shown, and a 24-hour monitored emergency response number, either the shipper's own staffed line or a registered emergency response service, with the contract number entered if one applies. A reprinted bill of lading takes the clerk five minutes.
If the shipper will not correct it, leave the load on the dock. Do not sign, do not stage the trailer half-loaded while you argue, and do not take the receiver's closing time as a reason to move. Call your supervisor and get the refusal documented in writing, with the time, the name of the clerk, and the specific defects. The exposure is not theoretical: an improperly prepared shipping paper and an unmonitored emergency number are each violations, and the driver who accepted the load is part of the chain. There is also a practical reason. If a drum fails on the highway at 03:00, the only number on the paper rings a desk that is empty, and the responders at the scene are standing next to a corrosive release with nobody to tell them what is in the trailer.
3. What do you do about the bulged drum with crust around the bung, and what is the reasoning?
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Refuse that drum. A bulged steel drum is a pressure vessel that has already failed somewhere. With hydrochloric acid the most likely causes are internal corrosion generating hydrogen gas, or a bung that is not sealing and has been weeping long enough to build the crust. Either way the packaging is no longer in proper condition for transport, it may not be offered, and it must not be loaded.
The crust is the tell. Dried white residue around the bung means the closure has been leaking and the threads and gasket behind it are corroded, so a second trip at highway speed and 94 degrees is exactly the condition that turns a weep into a rupture. Ask the shipper to replace the drum or overpack it in a compatible salvage packaging, and have the bill of lading corrected to match what actually loads. Photograph the drum and the crust before it leaves the dock, and note the exception so the receiver is not surprised. If the shipper insists it is fine, that is another reason to leave the whole load where it sits.