Shipping papers and emergency response information

Labels and placards tell people the hazard class at a glance. The shipping paper tells them exactly what is on board, how much, who sent it and who to call. Under 49 CFR 172.200 to 172.205, a shipping paper must accompany almost every hazmat shipment that is not covered by an exception. It travels with the carrier, is kept in a set place in the vehicle and is the first thing responders ask for at an incident. Under 172.600 to 172.604, emergency response information and a 24-hour emergency response telephone number must also be available whenever hazmat is in transport.

What the document must contain

The HMR set out the required information but not a fixed form, so shipping papers can be bills of lading, waybills, manifests or electronic records, as long as they contain everything required and are legible. Hazmat entries must be listed first, or highlighted in a contrasting color, or marked with an X in a column headed HM, so they stand out from non-hazardous items. For each hazardous material, the shipping paper must show the following:

The shipper's certification under 172.204 confirms that the person preparing the shipment has done everything required. The standard wording is: 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. Air shipments use a slightly different statement. Signing it is a legal declaration, not a formality.

Where the document goes

For highway transport, the shipping paper must be within the driver's immediate reach while the driver is at the controls, and either readily visible to a person entering the cab or kept in a holder on the inside of the driver's door. When the driver is away from the vehicle, it must be on the driver's seat or in the door holder. This lets a responder find it quickly even if the driver is hurt or away. For rail, a crew member must have it; for air and vessel, it goes with the cargo documents. Shippers must keep a copy for two years after the carrier accepts the shipment (three years for hazardous waste), and carriers must keep theirs for one year.

The emergency telephone number

Under 172.604, the shipping paper must show an emergency response telephone number, including the area code, that is monitored at all times while the material is in transport. The person answering must be knowledgeable about the material and its hazards, or have immediate access to someone who is. The offeror can list its own number or the number of an emergency response information provider, such as CHEMTREC, if it is registered with that provider, in which case the offeror's name or contract number must also appear. A number that goes to voicemail or an office closed at night does not meet the requirement.

Emergency response information

Under 172.602, emergency response information must accompany the shipment and be immediately available. It must describe the immediate health hazards, the risks of fire or explosion, immediate precautions, firefighting methods, initial handling of spills or leaks, and first aid. Most carriers meet this by carrying the Emergency Response Guidebook (ERG), currently the 2024 edition, together with the shipping paper; others carry a safety data sheet or an equivalent document. The August 2026 rules allow carriers to keep this information electronically, as long as it is immediately accessible. Lesson 11 explains how to use the ERG.

Emergency response plans for the most hazardous materials

The HMR do not have a direct equivalent of Canada's ERAP, but several rules serve similar purposes. Carriers and shippers of placarded quantities and certain highly hazardous materials must register annually with PHMSA and must have a security plan under 172.800 if they handle the listed materials. Railroads moving high-hazard flammable trains must give state emergency response commissions information about their routes and volumes, and must have oil spill response plans for large volumes of crude oil. Shippers commonly contract with emergency response providers, such as CHEMTREC, and with response contractors who can bring equipment to a scene. When shipments enter Canada, Canadian ERAP rules apply, so cross-border shippers of goods with an ERAP index must have an approved ERAP or join one.

# Check a draft shipping document entry for required elements (simplified).
REQUIRED = ["un", "name", "class", "pg", "quantity", "containers"]
entries = [
    {"un": "UN1203", "name": "GASOLINE", "class": "3", "pg": "II", "quantity": "160 L", "containers": "8 jerricans"},
    {"un": "UN1075", "name": "PETROLEUM GASES, LIQUEFIED", "class": "2.1", "quantity": "", "containers": "4 cylinders"},
    {"un": "UN3480", "name": "Li-ion batteries", "class": "9", "quantity": "60 kg", "containers": "3 boxes"},
]
NO_PG = {"2.1", "2.2", "2.3", "7", "6.2"}
OFFICIAL = {"UN1203": "GASOLINE", "UN1075": "PETROLEUM GASES, LIQUEFIED", "UN3480": "LITHIUM ION BATTERIES"}
for e in entries:
    problems = [f for f in REQUIRED if not e.get(f) and not (f == "pg" and e["class"] in NO_PG)]
    if e.get("pg") is None and e["class"] in NO_PG:
        problems = [p for p in problems if p != "pg"]
    if e["name"].upper() != OFFICIAL[e["un"]]:
        problems.append("shipping name not as listed")
    if e["class"] == "9" and "pg" in problems:
        problems.remove("pg")  # many class 9 battery entries have no packing group
    print(e["un"], "OK" if not problems else "missing or wrong: " + ", ".join(problems))

UN1203 OK
UN1075 missing or wrong: quantity
UN3480 missing or wrong: shipping name not as listed

The checker finds two errors that inspectors often see: a quantity left blank and an abbreviated shipping name. Real documents are checked line by line against the dangerous goods list, and many companies use software that fills in the description from the list to avoid typing errors.

Errors inspectors find most often

Roadside and facility inspections turn up the same document errors again and again. Knowing them makes them easy to avoid:

• A blank or estimated quantity, or a quantity without a unit.
• Shipping names that are abbreviated, misspelled or replaced with trade names.
• Generic N.O.S. entries without the required technical names.
• Packing groups missing, or written with Arabic numerals instead of Roman numerals in a way that causes confusion.
• An emergency telephone number that is not answered at all hours, or belongs to someone who knows nothing about the product.
• A missing or unsigned certification statement.
• Documents kept in the sleeper berth, a toolbox or the trailer instead of within the driver's reach.

Electronic records are increasingly accepted. The August 2026 rules allow carriers to keep emergency response information electronically, as long as it is immediately accessible, and allow motor carriers to carry their PHMSA registration certificate electronically. Responders still need to read the hazmat information immediately at a crash scene, even if the driver is injured and the truck has no power, so most highway carriers keep a paper shipping paper in the cab. Many shippers use software that fills in descriptions from the table automatically, which removes typing errors as long as the product data behind it are correct.

Treat the document as safety equipment. A responder who reads a correct document can choose the right guide, the right isolation distance and the right extinguishing method in seconds; one who reads a wrong document may choose all three wrongly.

Documents for multi-stop routes

Delivery routes with several stops add a complication: the document must always match what is on the vehicle. As goods come off at each stop, the driver should mark the document or use a separate document for each consignee, and the placards must be updated when a class leaves the vehicle or when the total drops below a placarding threshold. A responder who arrives at a crash at the fifth stop needs to know what is still on board, not what was loaded in the morning. Many carriers give drivers a stop-by-stop list showing the remaining dangerous goods after each delivery, which also helps the driver keep the placards correct.

Documents for returns need the same care. When a customer sends back partly used cylinders, damaged packages or unwanted products, the driver becomes the carrier of a new shipment, and the customer becomes its consignor. A document must be prepared for the return trip unless an exemption applies, and damaged packages may need special handling or salvage packaging.