Is your ecommerce merchandise considered hazardous materials? You are about to find out what that means, and how it might affect your daily business operations.
First of all, any substance that is flammable or combustible, pressurized, corrosive, radioactive, or infectious is considered a hazardous material (or hazmat, for short). While you may not be in the business of selling combustible materials, like lithium for example, all sorts of toys, electronics, and household items contain lithium-ion batteries, from cordless toothbrushes to vaping devices. Extra care must be taken when storing, handling, packing, and shipping these and other hazmat products.
What do you, as an ecommerce business owner, need to know about shipping hazmat products? This quick tutorial will answer all your questions.
Who’s in Charge of Hazmat Regulations?
The US Department of Transportation is responsible for designating materials as hazardous, and it issues regulations for the safe transportation and security of hazardous material in intrastate, interstate, and foreign commerce. Five separate agencies under the USDOT handle the administration and enforcement of these regulations.
- The Pipeline and Hazardous Materials Safety Administration (PHMSA) develops and enforces the Code of Federal Regulations Title 49 (49 CFR) that regulates the operation of the nation’s pipelines and nearly 1 million daily shipments of hazardous materials by land, sea, and air. Companies that “offer for shipment” (in this case, your ecommerce business) and shipping carriers that transport hazmat goods of certain quantities and types must register annually with the PHMSA and pay annual fees. PHMSA has a lot to say about how hazmat products should be handled and shipped, even if your shipments don’t require registration. A published version of 49 CFR consists of nine volumes and 900+ pages. No, you don’t need to read the whole thing. But you do need to make sure that everyone has the proper training and certification to handle hazmat products.
- The Federal Motor Carrier Safety Administration (FMCSA) regulates the highway routing of hazardous materials. It also issues hazardous materials endorsement (HME) for a commercial driver’s license and highway hazardous material safety permits.
- The Federal Railroad Administration (FRA) oversees the movement of hazardous materials by US rail.
- The Federal Aviation Administration (FAA) issues regulations covering hazardous materials that are part of the required aircraft equipment or radioactive materials transported for research, medical diagnosis or treatment purposes.
- The US Coast Guard (USCG) USCG regulates the bulk transportation of unmarked and unpackaged hazardous materials (such as oil tankers) by vessel.
USDOT maintains classifications for different types of hazardous materials. If you know your product’s hazmat classification, you can find the regulations that cover how they should be safely handled when storing, packing, and shipping. So, how do you determine your product’s hazmat classification?
1. Find Your Product Safety Data Sheet
Also called a Safety Data Sheet (SDS), the Product Safety Data Sheet is supplied by the product manufacturer or supplier, and contains all the data concerning the physical, chemical, explosive or radioactive properties of the hazardous materials or components. Your product’s hazard status and classification can be found under “Transportation Information” on this sheet. You will also need to know the product’s ID number, proper shipping name, and packing group.
There are nine classifications for hazardous materials, with a few examples of each. It is by no means a comprehensive list, but does give you an idea of the differences between the classes.
Class 1: Explosives (ammunition, gunpowder, fireworks)
Class 2: Gasses (hairspray, fire extinguishers, spray paint)
Class 3: Flammable and Combustible Liquid (gasoline, nail polish, paint thinner)
Class 4: Flammable Solid, Spontaneously Combustible, and Dangerous When Wet (coal, matches, sulfur)
Class 5: Oxidizer and Organic Peroxide (bleach, chlorine, hydrogen peroxide)
Class 6: Poison and Poison Inhalation Hazard (arsenic, biomedical waste, nicotine)
Class 7: Radioactive (Medical isotopes, x-ray machines)
Class 8: Corrosive (Drain cleaner, mercury thermometers, paint stripper)
Class 9: Miscellaneous (Dry ice, lithium-ion batteries, vehicles)
Common Hazmat Products in Ecommerce
As a full-service third-party logistics (3PL) and fulfillment provider, ShipMonk handles fulfillment and domestic shipping of hazmat products. (Many fulfillment centers don’t.) Here are some common products we handle that are considered hazardous or potentially hazardous materials.
- Paints/Primer (includes nail polish)
- Hair dyes
- Essential oils
- Antiseptics and disinfectants
- Insect repellents
- Shaving creams or foams
- Hand sanitizer
- Cleansers and cleaners
- Dishwashing liquids and powders
- Ink, cartridges, and toners
- Tape, adhesives, and glue
- Any aerosol product
Your Responsibilities as a Hazmat Shipper
As the owner of the ecommerce business and the products being shipped, you are responsible for ensuring that your products are classified, handled, packaged, labeled and shipped properly as they move through your supply chain. Everyone from the manufacturer to your warehousing and fulfillment teams, freight and shipping companies, truck drivers and mail carriers, all need to be trained and certified to handle hazardous contents. For this reason, it’s best to check and double-check with your manufacturer, state regulators, and USDOT to make sure that you have the correct classification, and understand the regulations that cover your product.
2. Consult the Hazardous Materials Table
Once you know your product’s hazmat classification, consult the hazardous materials table for specific regulations, provisions and exemptions that apply to your product. The table will direct you to specific requirements pertaining to labeling, packaging, quantity limits and stowage of hazmat products.
3. Consult your Freight or Shipping Carrier
Your shipping carrier will likely have its own hazardous materials restrictions and requirements. UPS, USPS, FedEx, and DHL all ship hazmat, but their requirements and restrictions will vary. Some hazmat products are forbidden, some may be restricted to a certain quantity or method of transport, and others may be transported as long as all the rules are followed. Depending on the size and contents or your shipment, some carriers might require a separate contract in order to ship dangerous goods, such as products containing lithium batteries.
4. Packaging and Labeling
A certification is required for anyone who handles hazmat materials. That includes the warehouse teams that receive and restock hazmat products, and the pickers and packers that fulfill your orders. As the owner of the merchandise, your ecommerce business is responsible for making sure that all “pre-transportation” functions are carried out in accordance with 49 CFR regulations. These functions include meeting standards for performance-oriented packaging and filler, proper labeling and UN marking, package inspection, training, emergency response information, and completed shipping documentation.
For marking and labeling, refer to PHMSA’s guide to hazardous materials markings, labeling and placarding. PHMSA also publishes a lithium battery guide that covers the marking and labeling requirements for products that contain all types of rechargeable batteries.
The good news is that a top-tier fulfillment company such as ShipMonk is certified to handle hazardous materials and can manage all of this for you. Though you are still ultimately responsible for the proper packaging, handling and labeling of your goods, you can trust that your products are in expert hands.
Only trained personnel — or those under the direct supervision of someone who is trained — are allowed to handle dangerous goods. Make sure your fulfillment center is certified to handle hazmat products.
In addition to following the packaging and shipping regulations issued by the USDOT, your warehouse or fulfillment center must follow regulations that govern the safety of its workers and the environment. These include the general safety requirements of the Occupational Safety and Health Administration (OSHA 29 CFR 1910.176) and storage requirements from the National Fire Protection Association Code 30 (NFPA 30) for flammables and combustibles. There are regulations that govern how and where goods must be stored to prevent accidental spillage, crushing, excessive heat, or contamination with incompatible materials (such as acids and bases, or water-reactive batteries and aqueous solutions). Emergency procedures must be posted where employees can quickly find them.
Your inbound freight carrier and outbound shipping companies must be registered with the PHMSA and display a hazardous materials safety permit (HMSP). Truck drivers must obtain and maintain Hazardous Materials Endorsement (HME) attached to their state-issued commercial driver’s license. Functions that are regulated by PHMSA regulations include:
- 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
Again, the good news is that any hazmat-certified 3PL fulfillment company such as ShipMonk will have close relationships with hazmat-certified shipping companies and will direct your shipments to these carriers only, handling the matter on your behalf within government regulations.
7. Do the Paperwork
Before you enter into a partnership with any 3PL or fulfillment company, you will need to submit the proper documentation for your products including:
- A completed SDS
- The number of units to be stored per facility
- The number of units shipped per package
- The capacity (if liquid) of each receptacle
A hazmat specialist will review the information and provide available inbound shipping methods and labeling requirements. Once approved and labeled properly, the fulfillment center can safely receive inventory and begin order fulfillment. Whether you’re partnering with a 3PL or fulfilling your own orders, you will need to supply the shipping company with the following information for each shipment.
- A description of the hazmat product
- The identification number and proper shipping name
- The hazard class and packaging group
- The total quantity of hazmat materials, including number and type of packaging
- Your hazmat certification and emergency contact information
Some of this information will be included on the Safety Data Sheet mentioned above, but each shipment will require its own manifest indicating the quantity and type of hazmat products being shipped. Depending on the exact nature of the package contents, additional paperwork may be required — check the Code of Federal Regulations to see if that’s the case. Examples of additional paperwork might include a signed dangerous goods contract, or a UN38.3 certificate indicating that the battery enclosed has been tested according to United Nations guidelines for safe transport.
Your To-Do List
The bottom line is that if your ecommerce business sells products that contain hazardous materials, it is your responsibility to understand and follow the federal regulations that affect handling and shipping. So, where do you start? With this to-do list!
1.) Find your Safety Data Sheet.
2.) Identify your product’s hazmat classification.
3.) Ensure proper packaging and labeling of your products for bulk inbound shipments and outbound customer orders.
4.) Ensure that every entity in your supply chain is trained and certified to handle hazmat products.
5.) Do the paperwork that ensures the safe transport of your products.
It may seem overwhelming, but the good news is you have a lot of resources at your fingertips, and help is just a click away. If you want to learn more about outsourcing order fulfillment to a hazmat-certified 3PL, contact ShipMonk today!
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