There are very specific rules for naming HAZMAT items on DOT shipping papers. One particular scenario is when you have a MIXTURE of hazardous and non-hazardous components making up that DOT material you wish to ship. How do you properly name it? To find out, let’s read below.
As you review the Code of Federal Regulations, the § 172.101 Purpose and use of the hazardous materials table provides the following information:
(10) Mixtures and solutions.
(i) A mixture or solution meeting the definition of one or more hazard class, that is not identified specifically by name in the Table, comprised of a single predominant hazardous material identified in the Table by the technical name and one or more non-hazardous material, must be described using the proper shipping name of the single predominant hazardous material and the qualifying word “mixture” or “solution”, as appropriate, unless one of the following conditions in A through F would be otherwise applicable to the mixture or solution:
(A) Except as provided in § 172.101(i)(4) the packaging in Column 8 is inappropriate to the physical state of the material;
(B) The shipping description indicates that the proper shipping name applies only to the pure or technically pure hazardous material;
(C) The hazard class, packing group, or subsidiary hazard of the mixture or solution is different from that specified for the entry;
(D) There is a significant change in the measures to be taken in emergencies;
(E) The material is identified by special provision in Column 7 of the § 172.101 Table as a material poisonous by inhalation; however, it no longer meets the definition of poisonous by inhalation or it falls within a different hazard zone than that specified in the special provision; or
(F) The material can be appropriately described by a shipping name that describes its intended application, such as “Coating solution”, “Extracts, flavoring” or “Compound, cleaning liquid.”.
(ii) If one or more of the conditions in paragraphs (c)(10)(i)(A) through (F) of this section is in fact satisfied, then the proper shipping name selection process in (c)(12)(ii) must be used as described hereafter.
(12) Except when the proper shipping name in the Table is preceded by a plus (+) a “mixture” or “solution” meeting one or more of the conditions in 172.101(c)(10)(i)(A – F) must be named as follows:
(ii) Generic or n.o.s. descriptions. If an appropriate technical name is not shown in the Table, selection of a proper shipping name shall be made from the generic or n.o.s. descriptions corresponding to the specific hazard class, packing group, hazard zone, or subsidiary hazard, if any, for the material. The name that most appropriately describes the material shall be used, e.g., an alcohol not listed by its technical name in the Table shall be described as “Alcohol, n.o.s.” rather than “Flammable liquid, n.o.s.” Some mixtures may be more appropriately described according to their application, such as “Coating solution” or “Extracts, liquid, for flavor or aroma,” rather than by an n.o.s. entry, such as “Flammable liquid, n.o.s.” It should be noted, however, that an n.o.s. description as a proper shipping name may not provide sufficient information for shipping papers and package markings. Under the provisions of subparts C and D of this part, the technical name of one or more constituents (i.e., at least one hazardous constituent) that makes the product a hazardous material is required in association with the proper shipping name.
For example: you have a liquid flammable mixture of acetone (DOT hazardous substance) with water (a DOT non-regulated substance) having a different packing group (i.e., lower hazard) than the listing for acetone due to the water component.
The proper DOT Name is not “acetone solution”, rather name it: UN1993, flammable liquid, n.o.s. (acetone), 3, III
*** In such cases, do NOT include the word, “mixture” or “solution” in the shipping name (i.e., for generic names)
Remember, The DOT has a very specific rule for naming any DOT Hazardous Material that also contains a non-hazardous component. Exceptions to this rule can be found at 49 CFR 172.101(c)(10)(i)(A)-(F).
References :
eCFR system – National Archives, Code of Federal Regulations. “§ 172.101 Purpose and use of the hazardous materials table”. Accessed 7 Jan. 2025. https://www.ecfr.gov/current/title-49/section-172.101.
Lion Technology. “When to Modify a Hazmat Shipping Name”. Access 7 Jan. 2025. https://www.lion.com/lion-news/august-2021/when-to-modify-a-hazmat-shipping-name
Article written by Robert Braman. Enviro-Safe Resource Recovery.
