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The Paperwork Doesn't Match the Drum

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The Paperwork Doesn't Match the Drum

You are at a shipper's dock in Akron with eight 55-gallon drums. Each drum bears a CORROSIVE label and the marking "UN1760, Corrosive liquid, n.o.s., 8, PG II." The shipping paper, however, lists "UN3264, Corrosive liquid, acidic, inorganic, n.o.s., 8, PG III," 8 drums, 440 gallons, and gives an emergency response phone number. One drum also has "RQ" and "Marine Pollutant" marked on it, but the shipping paper has no RQ notation and no marine pollutant notation. The shipper says the labels and paper are "close enough" and that the UN numbers are interchangeable for corrosives. You have a 200-mile run. You must decide whether to sign and move.

1. Identify the discrepancies and explain why each matters.

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The first discrepancy is the UN number and proper shipping name: the drums say UN1760, Corrosive liquid, n.o.s., while the paper says UN3264, Corrosive liquid, acidic, inorganic, n.o.s. Those are different entries and are not interchangeable. The second is the packing group: the drums say PG II, the paper says PG III. Packing group affects packaging strength, quantity limits, and emergency response, so a mismatch is not cosmetic. The third is the RQ marking on one drum: if the package contains a reportable quantity of a hazardous substance, the shipping paper must carry the RQ notation and identify the substance. The fourth is the Marine Pollutant marking: a marine pollutant notation is required when applicable. A driver who signs this paper is certifying a description that does not match the packages. That can lead to wrong placards, wrong emergency instructions, and a violation at the first inspection.

2. What must the shipper correct before you move, and what is your role?

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The shipper must reconcile the package markings, labels, and shipping paper so they describe the same material. That means correcting either the drums or the paper, not splitting the difference. The corrected paper should show the proper UN number and proper shipping name, the correct hazard class and packing group, the total quantity, the number and type of packages, and a usable emergency response telephone number. If the RQ marking is correct, the paper needs the letters RQ and the name of the hazardous substance; if the marine pollutant marking is correct, the paper needs the marine pollutant notation. My role is to verify, not to alter the shipping paper or choose a UN number myself. I would hold the load at the dock, explain the specific mismatch, and ask for a corrected document and matching package markings. If the shipper cannot resolve it, I would notify my carrier and refuse the load.

3. If the load is corrected, what placards and package checks do you make before departure?

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With 440 gallons of a Class 8 corrosive, the load is well above the 1,001-pound Table 2 threshold, so the trailer needs a CORROSIVE placard. I would verify the placard is on both sides and both ends of the vehicle. On the drums, I would check that the UN number and proper shipping name match the corrected paper, that the CORROSIVE label is present and legible, and that the RQ and Marine Pollutant markings, if still applicable, are consistent with the paper. I would inspect for leaks, loose bungs, dents, and staining, and I would reject any damaged drum. I would also confirm the emergency response phone number is reachable and that the shipping paper is accessible in the cab. Only then would I sign and move. The principle is simple: the paper, the package markings, the labels, and the placards must tell the same story.