Shipping papers 101: what goes on a hazmat BOL
The five required elements, the emergency contact rule, and who signs the certification statement.
Hazmat Shipping Papers: The Bill of Lading
A hazardous materials shipping paper is a legally binding document. Errors here are the leading cause of detained trucks and DOT fines. Every hazmat BOL must contain specific elements, presented in a strict sequence under 49 CFR Part 172, Subpart C.
The 5 Required Elements
Under 49 CFR 172.202, the basic description of a hazardous material must include these five elements in this order:
- UN/NA Identification Number: Exactly as it appears in the Hazardous Materials Table (e.g., UN1263). The "UN" or "NA" prefix is mandatory and must appear before the number.
- Proper Shipping Name (PSN): Exactly as listed in 49 CFR 172.101, not a trade name or common name (e.g., "Paint" not "AcmeCoat Industrial Coating").
- Hazard Class or Division: The primary hazard class number (e.g., 3). If the material has a subsidiary hazard, it appears in parentheses after the primary class: "3 (6.1)".
- Packing Group: Assigned in Roman numerals — PG I (greatest danger), PG II (medium danger), PG III (minor danger). Some materials (gases, explosives) have no packing group.
- Total Quantity: With units of measure, indicating net or gross weight (e.g., 500 kg, 110 lbs). The quantity must be specific — "a drum" is not compliant.
Example of a compliant description: UN1263, Paint, 3, PG II, 500 kg
Sequence and Highlighting Rules
The hazmat entry must either:
- Appear as the first entry on the shipping paper, OR
- Be highlighted in a contrasting color, OR
- Be identified by an "X" or "RQ" (Reportable Quantity) in a designated column labeled "HM."
This highlighting rule ensures that a driver — or an emergency responder — can immediately identify which line items are hazardous in a mixed shipment.
The Emergency Contact Requirement
Every hazmat BOL must include a 24-hour emergency response telephone number. The number must be:
- Monitored continuously while the material is in transit
- Answered by a person knowledgeable about the hazards of the material, or who has immediate access to such information
CHEMTREC (1-800-424-9300) is the most widely used third-party emergency response service. To list their number on your BOL, you must have an active contract with them — you cannot simply print the number without authorization.
The Shipper's Certification Statement
The shipper must include a signed certification that reads: "This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation."
This statement transfers significant legal responsibility to the shipper. It is the shipper — not the carrier — who certifies compliance with packaging and documentation requirements.
Retention Requirements
- Shippers must retain shipping papers for 375 days from the date of acceptance for ground transport.
- Carriers must retain them for 375 days from the date of delivery.
- For hazardous waste: retention is 3 years.
- Records must be retrievable and producible upon PHMSA request during an inspection.
Common Errors That Cause Truck Rejections
- Using a trade name instead of the Proper Shipping Name
- Omitting the "UN" prefix on the identification number
- Incorrect packing group (wrong Roman numeral)
- Missing or incorrect emergency contact number
- Quantity listed in units inconsistent with the material (e.g., gallons for a solid)
This guide is for educational purposes only. Always verify requirements against 49 CFR and consult your designated hazmat counsel before shipping.
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