49 CFR Hazmat Compliance Checklist for US Carriers

US domestic transport of hazardous materials is governed by Title 49 of the Code of Federal Regulations, Parts 100–185. The Pipeline and Hazardous Materials Safety Administration (PHMSA) writes and enforces the rules; FAA, FMCSA, FRA and USCG enforce them in their respective modes. This is a checklist, not a full course — work it from top to bottom for any shipment you originate.

1. Determine if the material is regulated (§172.101)

The Hazardous Materials Table in §172.101 is the master list. If a substance has an entry — or fits a generic / n.o.s. entry — and is not specifically excepted, it is regulated. Read the row in full: column 1 codes (A, W, D, I), the proper shipping name, hazard class, UN/NA ID, packing group, label codes, special provisions (column 7), packaging exceptions and authorisations, quantity limitations and vessel stowage requirements.

2. Classify the material (Part 173 Subparts C–G)

Each hazard class has its own classification rules in Subparts C through G of Part 173. Flammable liquids in §173.120, Class 8 corrosives in §173.136, lithium batteries in §173.185, and so on. Self-classification is the shipper's responsibility under §171.2.

3. Pick the right packaging (Parts 173 + 178)

• UN specification packaging built and marked under Part 178 is required for most fully regulated shipments.
• Non-bulk vs bulk:> 119 gal liquid / > 882 lb solid / > 1,000 lb water capacity gas = bulk packaging with additional Part 180 requirements.
• Salvage packaging §173.3, limited quantity §173.150–§173.156, and materials of trade §173.6 are common exceptions that reduce burden.

4. Mark the package (§172 Subpart D)

• UN identification number preceded by "UN" or "NA".
• Proper shipping name and technical name where required.
• Consignee or consignor name and address.
• Orientation arrows for liquids in combination packagings over 5 L inner.
• Marine pollutant mark, limited quantity mark, lithium battery mark as applicable.

5. Apply hazard labels (§172 Subpart E)

100 × 100 mm minimum, the correct primary class label, and any subsidiary risk labels required by column 6 of the HMT. Labels go on the same side as the marked information, near the proper shipping name where practicable.

6. Placard the vehicle (§172 Subpart F)

Placards are required on each side and each end of any motor vehicle or freight container that contains:

• Any quantity of a Table 1 material (e.g. explosives 1.1, dangerous when wet 4.3, poison inhalation hazard zones A and B, radioactive yellow III).
• 1,001 lb or more aggregate gross weight of any Table 2 hazard class.

DANGEROUS placard substitutes for two or more Table 2 classes when no single class exceeds 5,000 lb at one loading facility.

7. Prepare shipping papers (§172 Subpart C)

The paper must include, in this order:

1. UN identification number
2. Proper shipping name
3. Hazard class / division
4. Packing group in Roman numerals
5. Total quantity by mass or volume, including unit
6. Number and type of packages
7. Emergency response telephone number (§172.604)
8. Shipper's certification (§172.204)

For deeper coverage of how to read this paperwork — and where it most commonly goes wrong — see how to read a shipper's declaration.

8. Provide emergency response information (§172 Subpart G)

A 24-hour emergency response telephone number monitored by a person knowledgeable about the hazards (CHEMTREC, INFOTRAC or equivalent), plus written ER information either as the ERG entry or an equivalent document carried with the shipping paper.

9. Train every hazmat employee (§172 Subpart H)

General awareness, function-specific, safety, security awareness and in-depth security training (where required), plus modal training, on a recurring 3-year cycle. Records must be retained per §172.704(d).

10. Know the penalties

Civil penalties under 49 CFR §107.329 currently reach $96,624 per day per violation for hazmat transportation, with higher caps for violations resulting in death, serious illness, severe injury or substantial property destruction. See common hazmat shipping mistakes that cost $25,000+ for the practical pattern of enforcement actions.

For European road equivalents see the ADR beginner's guide.