When to Use the Proper Shipping Name "Corrosive Liquids, n.o.s." [49 CFR 172.101(c)]
If you ship hazardous materials, 49 CFR 172.101(c)(12) requires that you find a proper shipping name that corresponds the hazards of the material shipped. To select a proper shipping name, refer to the hazardous materials table at 49 CFR 172.101, and look for a proper shipping name that corresponds to the hazards of your material. Then follow these steps to choose the proper shipping name:
· If the name of the pure chemical (e.g., hydrochloric acid) is listed, and it corresponds the hazard, this is the name you must choose.
· If there is not a chemical name that corresponds to the hazard, look for an appropriate end use name (e.g., Battery fluid, alkali).
· If a chemical name or end use name is not available, select s shipping name based on the chemical family (e.g., Caustic Alkali Liquids, n.o.s.).
· If steps 1 - 3 do not produce a shipping name, a hazard class name (e.g., Corrosive Liquids, n.o.s.) can be used.
For example, consider a hazard class 8 corrosive liquid meeting the packing group II definition, with no secondary hazards. If your material is a mixture of several corrosive liquids, you'll choose a proper shipping name from the corrosive liquids family of names.
The hazmat table has numerous entries that start with "corrosive liquids...", such as:
· Corrosive liquid, acidic, inorganic, n.o.s. (UN 3264), or
· Corrosive liquid, acidic, organic, n.o.s. (UN 3265), or
· Corrosive liquid, basic, inorganic, n.o.s. (UN 3266), or
· Corrosive liquid, basic, organic, n.o.s. (UN UN 3267), or
· Corrosive liquid, n.o.s. (UN 1760)
You must choose the option that best suits the composition and properties of the material that you ship. Moreover, the material must meet the DOT's definition of a corrosive material before you use any of these shipping names. A material is corrosive if it can cause full thickness destruction of intact skin within 14 days after an exposure time of up to 4 hours; or a material that will corrode steel or aluminum surfaces at a rate greater than ¼ inch per year. Although pH might be a good indicator of potential corrosivity, unlike EPA, the DOT regulations do not specify pH ranges for corrosivity.
Unless the material is neutral (pH 7), you must choose one of the appropriate "acidic" or "basic" shipping names. If the constituents of the material are organic (contain carbon) use one of the "organic" shipping names.
To ensure that all of your hazardous materials are properly classified and shipped, attend Environmental Resource Center's Hazardous Materials Training - The Complete Course or webcast.