Where in the regulations does it allow the use of the old hazmat shipping sequence?

A question that is frequently asked is “Where in the regulations does it allow the use of the old hazmat shipping sequence on my shipping papers?” The regulations for the shipping sequence can be found in §172.202. However, this information is for the new sequence, with the identification number listed first. If you search through these shipping paper regulations, there is no mention of using the old sequence, with the proper shipping name listed first.

Section 171.14

The regulation allowing the use of the old sequence is not found in Part 172, but is instead found in Section 171.14, Transitional Provisions for Implementing Certain Requirements. Section 171.14 contains many compliance dates that are not found anywhere else in the hazmat regulations.

In §171.14, paragraph (e) contains the text allowing the use of the old hazmat shipping sequence. Paragraph (e) reads as follows:

(e) The shipping description sequences in effect on December 31, 2006, may be used until January 1, 2013.

What does this mean?

The shipping description sequence in effect on December 31, 2006, is the old sequence with the proper shipping name listed first.

A final rule for HM-215I changed the regulations so the sequence now has the identification number listed first. This change was effective (changed in the hazmat regulations) on January 1, 2007. So, the sequence in effect on December 31, 2006 is the old sequence with the proper shipping name listed first. The sequence in effect on January 1, 2007 is the new sequence with the identification number listed first.

What sequence can be used now?

Both hazmat shipping sequences may be used now for domestic transportation. The old sequence may be used until January 1, 2013. Starting in 2013, only the new sequence with the identification number listed first may be used.

For international transportation only the new sequence may be used.

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