The U.S. Department of Transportation (DOT) Hazardous Materials Regulations (49 CFR Parts 171–180) are a comprehensive set of regulations that govern the safe and secure transportation of hazardous materials. These regulations define the requirements for proper classification, hazard communication, packaging and handling of the hazardous materials. A shipper must determine whether a material is hazardous and, if so, exactly what hazard class, division, and packing group it belongs to before it can be offered for transportation. Non-compliance with these regulations can result in significant civil or criminal penalties.
The Classification of DOT hazard classes 1 through 8 is generally straightforward. Hazard class 9 is another story. Think of hazard class 9 as the “catch-all” class if you cannot classify a substance within classes 1 through 8. Hazard class 9 includes only the following materials (only these):
An item specifically listed on the DOT Hazmat table in 49 CFR 172.101 as a Class 9 hazardous material. Examples include the following (note: not all listings have a packing group):
- UN1845, dry ice, 9
- UN3480, lithium ion batteries, 9
- UN2950, asbestos, chrysotile, 9, III
An item having a RCRA waste code that does not fit within hazard classes 1 through 8. These will always have one of the following names. The name must be supplemented with at least one technical name of the specific chemical making the material hazardous:
- UN3077, environmentally hazardous substance, solid, nos
- UN3082, environmentally hazardous substance, liquid, nos
An item in a "bulk" package having a marine pollutant in excess of its threshold concentration of 1% or 10% from Appendix B of 49 CFR 172.101 that does not fit within hazard classes 1 through 8. Severe marine pollutants (PP) in Appendix B have a 1% threshold. Regular marine pollutants in Appendix B have a threshold of 10%. The Class 9 DOT proper shipping name must be supplemented with the words “Marine Pollutant” at the end of the shipping name after supplementing with the technical name of the specific listed marine pollutant. The following are some examples of the two possible shipping names:
- UN 3077 environmentally hazardous substance, solid, 9, III (alkyl dimethylamine), Marine Pollutant
- UN 3082 environmentally hazardous substance, liquid, 9, III (aldrin), Marine Pollutant
An item having a CERCLA hazardous substance listed in Appendix A of 49 CFR 172.101 in a single package over the CERCLA RQ amount that does not fit within hazard classes 1 through 8. The name must be supplemented with at least one technical name of the specific chemical making the material hazardous. The following are some examples of the two possible shipping names:
- UN3077, environmentally hazardous substance, solid, nos
- UN3082, environmentally hazardous substance, liquid, nos
Hazard Class 9 is intentionally broad, but it is not a “miscellaneous” class in the casual sense. It is a specific, regulated category for materials that pose environmental or other hazards not captured under hazard classes 1 through 8. By carefully applying the criteria in 49 CFR 171–180, shippers can ensure accurate hazard communication, prevent enforcement actions, and maintain compliance with DOT’s hazardous materials transportation requirements.
Article written by Robert Braman. Enviro-Safe Resource Recovery.
