The Hazardous Materials Table, or HMT, is the backbone of the Hazardous Materials Regulations. Understanding and knowing how to use the HMT is the first step toward compliance.
For each material listed, the 172.101 Hazardous Materials Table identifies each hazard class or specifies that the material is forbidden in transportation. It provides the proper shipping name of the material or directs the user to the preferred proper shipping name. In addition, the HMT specifies or references requirements pertaining to labeling, packaging, quantity limits aboard aircraft, and stowage of hazardous materials aboard vessels.
The Hazardous Materials Table usually referred to as the HMT or the Table, governs the transportation of hazardous materials by all modes air, water, rail and highway. It is important to use the Hazardous Materials Table correctly.
Column (1) may contain any one of six symbols: a plus sign(+) or the capital letters "A", "D", "G", "I", and "W".
Column 2 of the HMT contains proper shipping names are found in Column 2. Look closely at the two types of lettering, Roman and Italic. Proper shipping names are written in Roman type only. It is critical that the proper shipping name be spelled correctly on shipping papers. Proper shipping names in italics may not be used to describe hazardous materials.
Words in italics are not part of the proper shipping name, but may be used in addition to the proper shipping name. Find the proper shipping name Blue asbestos. Notice the entry Blue asbestos or Brown asbestos. The italicized or means that any of the terms in the sequence may be used as part of the proper shipping name, as appropriate.
The word “see” after a proper shipping name entry refers to another entry. If both names are in Roman type, you may use either name as the proper shipping name. Find the shipping name “Ethyl alcohol.” Notice that “Ethyl alcohol” is in Roman type and has no hazard class or division or identification number. However, the italicized word “see” refers you to “Ethanol;” Find “Ethanol.” This is where the hazard class or division and the ID No. are located. You may use either “Ethyl alcohol” or “Ethanol” as the proper shipping name since both names are in Roman type.
The words “poison” or “poisonous” may be used interchangeably with the word “toxic” when only domestic transportation is involved. When international transportation is involved, only the word “toxic” may be used.
The name on this drum. "Flammable liquids, n.o.s."
Is it a proper shipping name? Yes, “Flammable liquids, n.o.s.” is listed in Column 2 of the HMT in Roman letters and is a proper shipping name.
Except for hazardous waste, when qualifying words are utilized as part of the proper shipping name, their sequence in the package markings and shipping paper description is optional; however, the entry as shown in the HMT is the preferred sequence. Qualifying words shown in italics are not part of the proper shipping name. For example, for the entry “Paint related material including paint thinning, drying, removing or reducing compound, 3, UN 1263, PG I”, the qualifying words shown in italics are not required to be shown as part of the proper shipping name.
When the material is a hazardous waste and the word “waste” is not included in the HMT description, the word “waste” must be placed before the proper shipping name. For example, Acetone would become Waste Acetone. The word “waste” need not precede a proper shipping name that already includes the word “waste”. “Hazardous waste, liquid, n.o.s.” or “Hazardous waste, solid, n.o.s.” are two examples that do not require the addition of the word waste.
Under certain conditions, a mixture or solution not identified specifically by name, comprised of a hazardous material identified in the HMT by technical name, and a non-hazardous material, must be described using the proper shipping name of the hazardous material and the qualifying word “mixture” or “solution”, as appropriate
Column 3 of the HMT contains a designation of the hazard class or division corresponding to each proper shipping name, or the word “Forbidden”. Forbidden means that the material may not be offered for transportation or transported. This prohibition does not apply if the material is diluted, stabilized, or incorporated in a device, and it is classed in accordance with the definitions in Part 173 of the HMR. When test data or new data indicates a need to modify the “Forbidden” designation, the data must be submitted to the Associate Administrator for Hazardous Materials Safety for approval.
The hazard class of a hazardous material is indicated either by its class (or division) number, its class name, or by the letters “ORM-D”. The table contained in 173.2 lists the class numbers, division numbers, class or division names and those sections of the subchapter, which contain definitions for classifying hazardous materials, including forbidden materials.
When the entry for combustible liquids in Column 3 references
Class 3, each reference to a Class 3 material must be modified to read
“Combustible liquid” when reclassed in accordance
Column 4 of the HMT lists the 4digit identification number assigned to each proper shipping name. These 4digit numbers provide quick identification of all hazardous materials. It is critical to emergency responders that the numbers are accurate and that they are correctly written and legibly displayed.
Identification numbers preceded by “UN” for United Nations are descriptions of materials for domestic and/or international shipments, while identification numbers preceded by “NA” for North America may be used to describe certain materials when transported within the United States or between the United States and Canada.
Column 5 of the HMT specifies one or more packing groups assigned to a hazardous material. If a material is assigned to more than one packing group, the shipper must determine the correct packing group for the hazardous material. The packing group of the hazardous material will have an effect on a material’s packaging requirements. This grouping is according to the relative degree of danger presented by the hazardous material. Packing Group One indicates the greatest danger, while Packing Group Two indicates a medium level of danger, and Packing Group Three indicates a minor level of danger.
The packing group number must be indicated in Roman numerals on shipping papers, when applicable, and may be preceded by the letters “PG.” There are no packing groups for Class 2, Class 7, Division 6.2, and ORMD materials.
On shipping papers, the hazardous material must be accurately
described and identified in the proper sequence with the proper shipping name (
including the technical name, when
Column 6 of the HMT specifies label codes, which represent the hazard warning labels required to be applied to each package of hazardous material, unless excepted. If two label codes are listed, the first represents the primary hazard and the second represents the subsidiary hazard. Additional labeling requirements are found in 172.402.
Column 7 of the HMT specifies codes for special provisions applicable to packaging, packaging requirements, certification, and marking or labeling for a hazardous material. These special provisions are in addition to the standard packaging requirements.
Column 8 of the HMT specifies the applicable sections for packaging authorizations. Notice that Column 8 is divided into three parts - Column 8A, 8B and 8C. The sections cited under Columns 8A, 8B, or 8C are found in Part 173.For example: the number “211” in column 8B indicates that the specific nonbulk packaging requirements are found in 173.211. Also, the number “242” in Column 8C indicates that the specific bulk packaging requirements are found in 173.242.
When the packaging reference is not applicable to the form (solid or liquid) of the material being transported, use the Solid/Liquid Table in 172.101(i)(4) to determine the correct packaging.
Column 9 is divided into two columns and prescribes the maximum quantity limits for hazardous material transported in one package by either a passenger carrying aircraft or rail car, or by a cargo aircraft only.
Column 10, “Vessel Stowage,” is divided into two parts. Column 10A specifies the authorized stowage locations for hazardous materials on cargo and passenger vessels. Column 10B specifies vessel stowage requirements for specific hazardous materials. For more information about Column 10 and the five authorized stowage locations, please review Section 172.101(k).
Hazardous materials often fit more than one category, such as hazardous substance, marine pollutant, and hazardous waste. For example, Acetone, a Class 3 flammable liquid material is listed in Table I to Appendix A, and may meet the definition of a hazardous substance. Review 171.8 for more information on the definition for a hazardous substance.
Hazardous substances are listed in Table I - Appendix A to Section 172.101, “List of Hazardous Substances and Reportable Quantities.”
Now let’s determine if “Ethylene dichloride” is a hazardous substance. Locate the name “Ethylene dichloride” in the lefthand column of Table I - Appendix A. Follow across the page to the far right column, entitled “Reportable Quantity.” Reportable quantities are shown in pounds and kilograms. The RQ for Ethylene dichloride is 100 pounds or 45.4 kilograms per package. For this exercise, let’s assume we have 5,500 pounds of “Ethylene dichloride” in a cargo tank, which is one package. The material is not in a mixture or solution. Is the “Ethylene dichloride,” as packaged, a hazardous substance?
Answer these two questions. “Is the material listed in Table I - Appendix A?” Yes, it is listed. “Does the amount of material equal or exceed the RQ for “Ethylene dichloride?”