Shipping Paper and Emergency Response Number at the Bethlehem Consignor
You are a Pennsylvania CDL driver at a consignor in Bethlehem. The shipper hands you a shipping paper for 12 steel drums of UN1263 Paint, Class 3, PG II, gross 5,400 lb, and 4 fiberboard boxes of UN3480 Lithium ion batteries, Class 9, gross 480 lb. The paper reads: “Paint, 3, UN1263, II, 12 drums, 5,400 lb; Lithium ion batteries, 9, UN3480, 4 boxes, 480 lb.” The emergency response telephone is 610-555-0142, with a note “office hours 8–5, voicemail after.” The shipper says the number is fine because the plant is staffed during loading and the consignee will unload next morning. The batteries are marked with the lithium battery mark, but the paint drums have only a flammable liquid label; the paper has no emergency response information attached. You are asked to sign and leave before 17:00.
1. Is the emergency response telephone number acceptable for this shipment? Explain your reasoning.
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No. The emergency response telephone number must be monitored at all times while the hazardous material is in transportation, including nights, weekends, and holidays. The person or agency reached must either know the material and its hazards or be able to provide emergency response information. An office-hours number that rolls to voicemail after 17:00 fails that requirement. The fact that the plant is staffed during loading does not cover the line-haul or the overnight period before the consignee unloads. The driver should not accept the shipment until the shipper provides a continuously monitored number or contracts with an emergency response service that can answer at all times. The number also must be on the shipping paper, and the emergency response information must be available to the driver.
2. Are the basic descriptions on the shipping paper correct? Identify any corrections.
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The paint entry is close to a proper basic description: proper shipping name, hazard class, UN number, and packing group are present. The order is acceptable because the UN number may precede the proper shipping name. The lithium battery entry correctly omits a packing group because Class 9 lithium ion batteries are not assigned one. However, the paint drums need the proper shipping name and UN number marked on each package, not just a flammable liquid label. The paper also lacks the required emergency response information, such as immediate hazards, protective actions, and the emergency response telephone number. A telephone number alone is not the full emergency response information. Before departure, the shipper must correct the package markings and attach or provide the emergency response information in a form the driver can use.
3. What should you do before signing the paper and departing?
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Do not sign and depart on the paperwork as presented. First, require a 24-hour monitored emergency response telephone number and the emergency response information attached to or accompanying the shipping paper. Second, verify that each paint drum is marked with the proper shipping name and UN1263 and that the labels are correct and legible. Third, confirm the shipping paper is legible, in English, includes the total quantity and package count, and has the shipper’s certification. Fourth, check that the batteries are properly marked and labeled and that the paper matches the packages actually loaded. If the shipper cannot correct these items before departure, reject the load, notify your dispatcher, and document the refusal. Signing would make you part of moving a shipment with an inadequate emergency response number and deficient package markings.