Frequently Asked Questions (FAQs) For The Newly Trained Or Occasional Shipper
Where regulations are cited, it is strongly advised that the cited regulation be thoroughly reviewed for more detailed information. Unless otherwise indicated, all regulatory citations can be located in Title 49 of the Code of Federal Regulations (CFR). All responses relate to the transportation of hazardous materials by air.
- Marking and Labeling
- Documentation and Recordkeeping
- Shipper Accountability
What is a hazardous material?
A hazardous material is defined as a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce.
Who is required to be trained?
According to §172.702, "A hazardous materials (hazmat) employer shall ensure that each of its hazmat employees is trained in accordance with the requirements" of the regulations. Training is required for any person engaged in the pre-transportation functions, meaning a function that is required to assure the safe transportation of a hazardous material in commerce, including —
- Determining the hazard class of a hazardous material.
- Selecting a hazardous materials packaging.
- Filling a hazardous materials packaging, including a bulk packaging.
- Securing a closure on a filled or partially filled hazardous materials package or container or on a package or container containing a residue of a hazardous material.
- Marking a package to indicate that it contains a hazardous material.
- Labeling a package to indicate that it contains a hazardous material.
- Preparing a shipping paper.
- Providing and maintaining emergency response information.
- Reviewing a shipping paper to verify compliance with the HMR or international equivalents.
- For each person importing a hazardous material into the United States, providing the shipper with timely and complete information as to the HMR requirements that will apply to the transportation of the material within the United States.
- Certifying that a hazardous material is in proper condition for transportation in conformance with the requirements of the HMR.
- Loading, blocking, and bracing a hazardous materials package in a freight container or transport vehicle.
- Segregating a hazardous materials package in a freight container or transport vehicle from incompatible cargo.
- Selecting, providing, or affixing placards for a freight container or transport vehicle to indicate that it contains a hazardous material.
What does "hazmat employer" mean?
According to §171.8, a hazmat employer is "A person who employs or uses at least one hazmat employee on a full-time, part time, or temporary basis."
What does "hazmat employee" mean?
According to §171.8, a hazmat employee is any employee who is "Employed on a full-time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time or temporary employment directly affects hazardous materials transportation safety".
What areas are covered by the training?
§172.700 states that training "means a systematic program that ensures a hazmat employee has familiarity with the general provisions of this subchapter, is able to recognize and identify hazardous materials, has knowledge of specific requirements of this subchapter applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures."
How frequently must a hazmat employee be retrained?
Retraining of hazmat employees is critical for the continued safety of the aviation cargo community. For domestic air transportation, hazmat employees are required to be retrained at lease every three years (see §172.704). Under the International Civil Aviation Organization (ICAO) Technical Instructions (TI) for the Safe Transport of Dangerous Goods by Air, recurrent training is required every two years.
Where can my organization obtain appropriate hazardous materials training?
Organizations can obtain appropriate hazardous materials training through a variety of commercial sources. As the FAA is a government organization, it cannot endorse or recommend a specific vendor for training. However, vendors are readily available on the internet.
Can I conduct my own internal training?
Yes. As long as the information that is required by regulations is thoroughly reviewed and tested, organizations may conduct their own internal training.
Do training records need to be maintained?
Yes. Training records are required to be maintained and made available to FAA Hazardous Materials Safety Program personnel upon request.
How do I know the proper classification of a material I wish to ship?
Proper classification may be obtained through a variety of sources. These include, but are not limited to, the manufacturer of the material, laboratory testing and Safety Data Sheets.
Do I need to use specific types of packaging for the material I wish to ship?
Packaging requirements vary depending on the type, class and quantity of hazardous materials you are shipping. Often, packing must be tested and certified to meet the requirements of the regulations for shipment of hazardous materials by air.
Where can I obtain appropriate packaging for my material?
Packaging for the shipment of hazardous materials by air may be obtained through a variety of commercial sources. As the FAA is a government entity, we cannot endorse or recommend a specific supply source for packaging that will meet the regulatory requirements of your materials. However, vendors are readily available on the internet.
How do I communicate that my package contains a hazardous material?
Hazards are communicated using a series of markings and labels on the exterior of the package. The complete description of these requirements can be located in 49 CFR §172.300 (Marking) and §172.400 (Labeling).
What is the difference between a marking and a label?
Markings are generally considered to refer to the description of the material being transported that is displayed on the packaging. Labels are generally considered to include the standard hazard symbol that must be displayed.
Can I use pre-marked and labeled packaging?
Yes, as long as the markings and labels pertain to the contents and comply with the current regulations.
How can I obtain the proper markings and labels for my packaging?
Markings and labels for the shipment of hazardous materials by air may be obtained through a variety of commercial sources. As the FAA is a government entity, we cannot endorse or recommend a specific supply source for markings or labels. However, vendors are readily available on the internet.
What types of documentation do I need to provide to my carrier to communicate that my package contains hazardous materials?
Typically, you will be required to complete a shipper's declaration. This document must include the UN identification number, proper shipping name, hazard classification information, packing group, and quantity of the material. Specific details and additional information can be located in §172.200. In addition, a common format is available at the following URL:
Do I have to keep records of my hazardous materials shipments?
Yes. Hazardous materials shipper's declarations must be maintained for a period of twenty-four (24) calendar months. These documents must be made available to FAA Hazardous Materials Safety Program personnel upon request during inspections.
How will my compliance with the regulations for air transport be monitored?
Compliance with the regulations is monitored by inspections. These inspections are specifically designed to evaluate a shipper's compliance with the regulations, present the opportunity for immediate correction of non-safety related issues, and prevent hazardous materials related accidents or incidents aboard aircraft.
What happens if I fail to comply with the regulations for an air shipment?
Non-compliance with the regulations poses a serious safety risk to the public and the aviation industry. If you are found to have violated the regulations, a variety of penalties may be assessed. These penalties range from administrative action to a monetary civil penalty. Willful violations of the hazardous materials shipping regulations may be referred for appropriate criminal prosecution.
What happens if I discover that I have accidentally shipped an undeclared hazardous material by air?
You will most likely be visited by a member of the FAA Hazardous Materials Safety Program staff to review your processes, procedures and training. Depending on the circumstances, you may be assessed a penalty or receive counseling. In either event, shipments of undeclared hazardous materials pose a significant risk to the air transportation system and every effort must be made to prevent them.
What happens if there is an incident or accident with my package while it is being transported by air?
If there is an incident or an accident while your package containing hazardous materials is being transported, the emergency response information may be used to mitigate any hazards posed by the material. The emergency response information is required to be immediately available while a hazardous material is present and will be used by emergency personnel to properly respond to the situation.
What is meant by "emergency response information"?
"Emergency response information" means information that can be used in the mitigation of an incident involving hazardous materials and, as a minimum, must contain the information listed in §172.602.
Am I required to develop a security plan or program?
If you ship any of the commodities listed in §172.800, your organization is responsible for complying with the provisions of that section, and must develop a security plan.
Am I required to register with the US Department of Transportation?
Any person who offers for transportation or transports, in foreign, interstate or intrastate commerce the commodities listed in §107.601, is required to register with the US Department of Transportation.
Are the rules the same if I ship hazardous materials by air internationally?
While some of the international regulations are similar, shippers are cautioned that there are differences when shipping hazardous materials internationally. If a shipper wishes to transport hazardous materials internationally, they are required to be trained in and comply with the provisions found in the ICAO TI for the Safe Transport of Dangerous Goods by Air.
Is it required that all of the regulatory requirements be met if I am only shipping a small quantity of hazardous materials by air?
Some hazardous materials may be shipped by air in limited quantities. The requirements to ensure regulatory compliance can be found in §173.4b. Information regarding Excepted Quantities of hazardous materials can be located in §173.4a.
Who can I contact with questions about my air shipments?
Questions can be emailed to the FAA at HazMatInfo@faa.gov. Please allow up to 48 hours for a response. We will assess your inquiry and provide information to help guide you on your journey of enhancing aviation safety.
For general questions about transportation of hazardous materials, contact DOT's Hazardous Materials Information Center at 1-800-467-4922 or 202-366-4488, Monday through Friday from 9 a.m.-5 p.m. EST, or e-mail at email@example.com.