Just like Nigel Tufnel’s amp that went up to 11, the new DOT Chart 15 is one more than the DOT Chart 14 it just replaced, making it TWO more than the DOT Chart 13. Whatever the number the DOT Chart 15 is the latest version of a guidance document created by the PHMSA of the USDOT. It contains a wealth of information – both text and images – of three of the four hazard communication methods (Markings, HazMat Labels, & Placards; only Shipping Papers are missing) and is invaluable to anyone involved in the transportation of hazardous materials: shippers, carriers, receivers, HazMat Employers, HazMat Employees, training providers, etc. Given the amount of helpful information it contains regarding the hazardous material regulations (HMR) it is hard to believe that it is only four pages. The purpose of this article is to briefly explain the content in a DOT Chart 15 to the uninitiated and to provide direction to where you may obtain copies of it for yourself. Read the rest of this entry »
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The Hazardous Materials Regulations of the USDOT/PHMSA contain specific requirements for the description of a hazardous material on a shipping paper, known as the Proper shipping Description. One component of the Proper Shipping Description is the Basic Description; the purpose of which is to – just like the name implies – provide a basic description of the potential hazards presented by a material in transportation. This article will explain how a change to the order of the Basic Description (effective January 1st, 2013) affects other responsibilities of a HazMat shipper and a possible source of confusion when using the Uniform Hazardous Waste Manifest for the transportation of a hazardous waste. Read the rest of this entry »
Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings
Generally, one can assume that the use of the Identification Number in association with the placard for a shipment of a hazardous material is limited to those shipments that are or contain a bulk packaging.
- The transport vehicle itself is a bulk packaging of greater than 1,000 gallons (eg. tank truck or railroad tank car).
- A bulk packaging of any volume (eg. intermediate bulk packaging or IBC) is loaded into a transport vehicle where its identification number is no longer visible.
In either of the above, the Hazardous Material Regulations of the USDOT/PHMSA require that the transport vehicle be marked on both sides and each end with the identification number of the hazardous material. The identification number used must be determined from the Hazardous Materials Table and be displayed in association with the hazardous materials placard as required by §172.332 or §172.336 (either on an orange panel or a white square-on-point configuration).
You may wish to read this earlier article for an exception to this marking requirement for certain shipments of bulk packagings.
Often overlooked by shippers and carriers alike, however, is the requirement in 49 CFR 172.301(a)(3) to mark a transport vehicle or freight container containing only a single hazardous material in non-bulk packages, on each side and each end with the identification number specified for the hazardous material in the § 172.101 Table, as long as the following requirements are met:
- Each package is marked with the same proper shipping name and identification number;
- The aggregate gross weight of the hazardous material is 4,000 kg (8,820 pounds) or more;
- All of the hazardous material is loaded at one loading facility;
- The transport vehicle or freight container contains no other material, hazardous or otherwise; and
- The identification number marking requirement of this paragraph (a)(3) does not apply to Class 1, Class 7, or to non-bulk packagings for which identification numbers are not required.
Company A offers for shipment 20 x 55 gallon drums of Chromic Acid Solution weighing 11,009 pounds. The carrier makes the pickup of the Chromic Acid Solution and nothing else, and has no other material (hazardous or otherwise) loaded on the vehicle. In this situation, it is necessary to include the identification number for Chromic Acid Solution (UN1755) either on the placard or nearby as required by §172.332 or §172.336 (either on an orange panel or a white square-on-point configuration).
As you can see, the Hazardous Materials Regulations of the USDOT/PHMSA can be very complicated. Even the seemingly simple regulations pertaining to the use of the identification number marking on a transport vehicle or freight container can become difficult to comply with when certain situations arise. Training your HazMat Employees on the requirements of the HMR is a good way to ensure the transportation of hazardous materials to and from your facility is done safely and in compliance with the regulations.
The shipper of a hazardous material (HazMat) must ensure the correct hazard communication methods are used to identify the potential hazards posed by the material offered for transportation. The four hazard communication methods required by the US DOT when offering a hazardous material for shipment are:
- Shipping Papers
- HazMat Labels
Of these four, HazMat Labels and Markings are the methods a HazMat Employee is most likely to encounter during routine job duties since these are applied to the HazMat packaging itself. This article will address the general marking requirements for a non-bulk packaging of a hazardous material offered for transportation in commerce (49 CFR 172.301). Read the rest of this entry »
For those of you not familiar with the DOT Chart 14, it is a fantastic guidance document produced and distributed by the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the US DOT. It contains helpful information on three of the four hazardous material communication methods required by the Hazardous Material Regulations (HMR):
- Warning Labels, and;
The missing HazMat communication method is: Shipping Papers.
At just four pages, the DOT Chart 14 is not a comprehensive source of information, nor is it intended to be a substitute for the regulations; as it reads on the cover, “NOTE: This document is for general guidance only and should not be used to determine compliance with 49 CFR, Parts 100-185.” And don’t be misled by the translation to Spanish; the HMR requires all HazMat shipping papers, markings, warning labels, and placards to be in English. The intent, I imagine, of this translated version is to assist you as the HazMat Employer to fulfill the requirement to provide full training to your Spanish speaking HazMat Employees every three years (49 CFR 172, Subpart H).
The DOT Chart 14, both English and Spanish, is available from the following sources:
- Download and print a color copy from the PHMSA website for free (English or Spanish),
- Purchase a copy from a commercial supplier, or;
- Purchase a copy directly from the PHMSA for much less than you’ll spend at a commercial supplier.
I have used the DOT Chart 14 as a part of my HazMat Employee training for years, going back to when it used to be known as the DOT Chart 12 and was produced by the Research and Special Programs Administration (RSPA), precursor to the PHMSA. I strongly recommend its use to assist you in complying with the Hazardous Material Regulations at your facility.
An identification number, though usually displayed on or in association with a placard on a vehicle or bulk container, must be in compliance with the Marking requirements of 49 CFR 172, Subpart D and not the Placarding requirements of Subpart F. And it is in 49 CFR 172.334(d) that a little known prohibition on the use of the identification number on placarded vehicles can be found. Simply stated, the regulation prohibits the use of an identification number on a placard unless the identification number is applicable to all of the hazardous materials of the same hazard class in the vehicle.
Consider: A truck is to be loaded with the following hazardous materials…
- UN 3264, Waste Corrosive Liquid, Acidic, Inorganic, n.o.s (Hydrochloric Acid, Hydrogen Peroxide), 8, II – 6 x 55 gallon drums @ 600 lb/drum = 3,600 lbs
- UN1760, Waste Corrosive Liquid, n.o.s. (Nitric Acid, Hydrofluoric Acid), 8, II – 1 x 350 gallon bulk packaging = 350 lbs
Per the US Department of Transportation (US DOT) regulations at 49 CFR 172.504(c) a CORROSIVE placard is required on all four sides of the vehicle for two reasons: (1) the gross weight of the hazardous material shipment is >1,001 lbs and (2) a bulk packaging of a hazardous material is part of the shipment. Further, 49 CFR 172.331(c)mandates the use of the identification number on all four sides of the vehicle since the identification number on the bulk packaging (UN1760) is not visible inside the closed transport vehicle.
The usual response to this situation is to placard the vehicle CORROSIVE on all four sides with the identification number (UN1760) for the bulk packaging on the placard. All is well, right? Not so fast there Shipper! 49 CFR 172.334(d) prohibits the use of the identification number on the placard in this case. Why? Because the identification number on a placard may only be used if it represents all the hazardous materials in that hazard class loaded on the vehicle. Since the six drums of Waste Corrosive Liquid, Acidic, Inorganic, n.o.s. has an identification number of UN3264, you cannot use the identification number of UN1760 on the CORROSIVE placard. However, since 49 CFR 172.331(c) requires the use of the identification number on all four sides of the vehicle, you may use the applicable identification number on an orange panel near the CORROSIVE placard.
Pretty confusing huh? And what does it matter to you anyway? You’re a shipper of hazardous materials, not a carrier. Placarding is the responsibility of the carrier, right? Wrong. 49 CFR 172.506(a) reads: “Each person offering a motor carrier a hazardous material for transportation by highway shall provide to the motor carrier the required placards for the material being offered prior to or at the same time the material is offered for transportation, unless the carrier’s motor vehicle is already placarded for the material as required by this subpart.” And 49 CFR 172.300(a) reads: “Each person who offers a hazardous material for transportation shall mark each package, freight container, and transport vehicle containing the hazardous material in the manner required by this subpart.” Since you are offering the hazardous material (which includes hazardous waste shipped on a Uniform Hazardous Waste Manifest) to a motor carrier for transportation it is your responsibility to ensure the bulk packaging and vehicle are properly placarded and marked.
There are many aspects of DOT’s Hazardous Material Regulations (The HMR) that place the burden of responsibility on the person who offers hazardous materials for transportation in commerce (i.e. the Shipper). As a Shipper of hazardous materials – including hazardous waste – it is important for you to be familiar with all of your regulatory requirements.
My public training events held nationwide and year-round are designed to inform EHS and Transportation Managers of these responsibilities and to provide them with the tools to assist in maintaining compliance. My on-site training for only $1,749 and $10/trainee can focus on the site-specific needs of your company’s hazardous waste personneland HazMat Employees.