UN 3077 is the United Nations identification number for solid materials classified as environmentally hazardous substances, not otherwise specified. It sits in Class 9 of the U.S. Department of Transportation’s hazard classification system, always ships as Packing Group III, and triggers a specific set of labeling, documentation, training, and release-reporting obligations under 49 CFR. Getting any of those wrong exposes shippers to civil penalties that reach six figures per violation.
What UN 3077 Covers
Class 9 is the catch-all category in the UN hazardous materials system for dangerous goods that don’t fit the primary hazard classes like flammables, corrosives, or explosives.1eCFR. 49 CFR Part 172 Subpart B — Table of Hazardous Materials The “N.O.S.” in the proper shipping name — “Environmentally Hazardous Substance, Solid, N.O.S.” — stands for “Not Otherwise Specified.” It’s a grouping for any solid that meets environmental hazard criteria but has no dedicated UN number of its own. Every UN 3077 shipment sits in Packing Group III, the lowest transport-danger tier within the class.
The liquid counterpart is UN 3082, “Environmentally Hazardous Substance, Liquid, N.O.S.” The only difference is physical state: solid gets 3077, liquid gets 3082. Both are Class 9, both Packing Group III, and both trigger the same core obligations.2UNECE. Transport Provisions for Small Quantities of Environmentally Hazardous Paints, Printing Inks, and Related Materials The state at the time of transport controls which number applies.
How a Substance Qualifies
A solid gets classified as UN 3077 when it meets aquatic toxicity thresholds from the Globally Harmonized System (GHS) and hasn’t already been assigned to a higher hazard class (Classes 1 through 8). The trigger is any one of three GHS categories: Acute Aquatic Toxicity Category 1, Chronic Aquatic Toxicity Category 1, or Chronic Aquatic Toxicity Category 2.2UNECE. Transport Provisions for Small Quantities of Environmentally Hazardous Paints, Printing Inks, and Related Materials
Acute toxicity looks at short-term lethality to fish, invertebrates, or algae at low concentrations. Chronic toxicity captures harm over longer exposures and also factors in whether the substance persists in the environment and bioaccumulates up the food chain. Meeting one of those categories is enough.
Common Examples
Because it’s an N.O.S. entry, UN 3077 is not a single chemical but a wide range of solid materials. Frequently shipped examples include:
- Certain solid pesticides and herbicides toxic enough to aquatic life to meet the threshold.
- Contaminated soils, including soil containing traces of heavy metals like lead or arsenic shipped for remediation or disposal. A PHMSA interpretation letter addressed exactly this kind of shipment, described as “RQ, UN3077, Environmentally hazardous substance, solid, n.o.s., 9, PGIII, (lead, arsenic).”3U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration. Interpretation Letter Ref No 14-0102
- Solid forms of lead, arsenic, copper, and zinc compounds when they pose sufficient aquatic risk.
- Some micronutrient fertilizer additives containing concentrated metals like copper or zinc.
One boundary worth flagging: polychlorinated biphenyls are sometimes described as UN 3077, but PCBs have their own dedicated UN numbers — UN 2315 for liquids and UN 3432 for solids — so they don’t ship under the N.O.S. designation.4NOAA. Polychlorinated Biphenyls (PCB) – Chemical Datasheet The N.O.S. category applies only when no more specific entry exists in the hazardous materials table.
Labels, Marks, and Placards
Packages must carry a Class 9 hazard label: a diamond with seven black vertical stripes across the top half and the number “9” at the bottom, on a white background.5eCFR. 49 CFR Part 172 Subpart E — Labeling
Many UN 3077 substances also require a separate marine pollutant mark — a square-on-point with a black fish-and-tree symbol on white, placed next to the Class 9 label on non-bulk packages moving by vessel.6eCFR. 49 CFR 172.322 — Marine Pollutants It is not required on single packages or inner packages of 5 kg (11 pounds) or less for solids. The fish-and-tree mark and the Class 9 label are separate markings and are often confused.
Placarding has an important wrinkle. Under 49 CFR 172.504(f)(9), Class 9 placards are not required for domestic transportation within the United States.7eCFR. 49 CFR 172.504 — General Placarding Requirements Bulk packages still need identification number markings displayed on a Class 9 placard, orange panel, or white square-on-point, but the four-sided vehicle placarding that applies to most other hazard classes doesn’t apply here for domestic moves. International shipments, especially ocean transport under the IMDG Code, follow standard placarding rules.
Shipping Papers
Every UN 3077 shipment needs a shipping paper with a proper description. Because it’s an N.O.S. entry, the technical name of the actual hazardous substance must appear in parentheses after the proper shipping name. If the material contains two or more hazardous substances, at least two must be identified, with priority given to those with the lowest reportable quantities.8eCFR. 49 CFR 172.203 – Additional Description Requirements A typical entry reads: “RQ, UN 3077, Environmentally hazardous substance, solid, n.o.s., 9, PGIII, (lead, arsenic).”
“RQ” stands for reportable quantity and must appear when the shipment meets or exceeds the reportable quantity threshold for the specific hazardous substance. Reportable quantities range from 1 pound to 5,000 pounds depending on the material’s toxicity and persistence.9eCFR. 40 CFR Part 117 — Determination of Reportable Quantities for Hazardous Substances A release equal to or exceeding the RQ triggers immediate notification to the National Response Center.10U.S. Environmental Protection Agency. Hazardous Substance Designations and Release Notifications
Shippers and carriers keep copies after the shipment is complete: three years from the date the initial carrier accepted the material for hazardous waste, two years for other hazardous materials.11eCFR. 49 CFR 172.201 — Preparation and Retention of Shipping Papers
Training Requirements
Anyone who handles, packages, or signs shipping papers for UN 3077 qualifies as a “hazmat employee” and must complete training before performing those functions unsupervised. Five areas are covered:
- General awareness — recognizing and identifying hazardous materials.
- Function-specific training on the rules that apply to the employee’s actual job duties.
- Safety training on emergency response, hazard protection, and accident avoidance.
- Security awareness on recognizing and responding to potential threats. New employees must complete this within 90 days of starting.
- In-depth security training, required only for employees involved with a security plan.
All training must be repeated at least once every three years.12eCFR. 49 CFR 172.704 — Training Requirements Training violations accumulate fast because each untrained employee is a separate violation, and the minimum civil penalty for one is $617.
Penalties
Civil penalties for knowing violations of federal hazardous materials transportation law reach $102,348 per violation. If a violation causes death, serious injury, or substantial property destruction, the maximum rises to $238,809. Each day a continuing violation persists counts as a separate offense.13eCFR. 49 CFR 107.329 — Maximum Penalties
The same penalty structure covers packaging design, manufacture, testing, and certification. Shipping UN 3077 in packaging that wasn’t properly tested or certified for hazmat use draws the same exposure as a labeling or documentation failure. Because many UN 3077 materials move in ordinary-looking drums or boxes, the regulatory risk is easy to underestimate.
Spills and Releases
When a release occurs during transport, first responders work from the Emergency Response Guidebook. UN 3077 falls under ERG Guide 171, covering substances with environmental hazard concerns but relatively low immediate danger to humans compared to higher hazard classes.14Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S. Department of Transportation (DOT). 2024 Emergency Response Guidebook
The priority with these materials is containment: keeping the solid out of waterways, storm drains, and soil where it can leach into groundwater. The aquatic toxicity that earned the classification means even a modest spill reaching a stream or lake can cause outsized ecological damage. Responders use appropriate protective equipment and rely on physical containment methods such as berms, absorbent materials, and covers to prevent wind dispersal. Collected material must go to a licensed hazardous waste facility rather than into ordinary solid waste.
If the released quantity meets or exceeds the substance’s reportable quantity, the person in charge of the facility or vessel must immediately notify the National Response Center at 1-800-424-8802. Failing to report a release above the RQ is itself a separate violation with its own penalty exposure.