49 CFR 172.504 – General Placarding Requirements contains the applicability, scope, and general requirements for the use of placards when transporting a hazardous material. §172.504(a) identifies the five (5) types of packagings and modes of transportation that will require placards, unless excepted. A closer look at these five defined terms is important since packagings and methods of transportation not included in §172.504(a) will not require a placard. Read the rest of this entry »
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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 »
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.
Unless an exception to the Hazardous Material Regulations (HMR) is available, every shipment of a hazardous material will require the use of each of the four hazard communication methods of the US DOT, they are:
- Shipping papers
- HazMat labels
Typically a placard is affixed to all four sides of a transport vehicle, such as a truck on the highway or a rail car. There are some situations, however, where a placard is required to be affixed to all four sides of a bulk packaging and there are some situations where the use of a placard or a HazMat label is an option on two sides of a bulk packaging. You can read more about the option to placard or label bulk packagings here: Use of Placards for HazMat Shipments in Bulk Packagings.
The purpose of this article is to answer a question asked at one of my Public Training Seminars: “Is it OK to use a placard on a non-bulk packaging of a hazardous material in place of the HazMat label?” Read the rest of this entry »
49 CFR 172.504(a) states that when required each bulk packaging, freight container, unit load device, transport vehicle, or rail car “must be placarded on each side and each end”. 49 CFR 172.516(a,b) goes on to state that, “Each placard on a motor vehicle and each placard on a rail car must be clearly visible from the direction it faces, except from the direction of another transport vehicle or rail car to which the motor vehicle or rail car is coupled.”
A challenge complying with the relatively simple requirement to placard all four sides and be done with it arises when separate transport vehicles or rail cars are coupled together for a shipment of hazardous materials. It is quite possible that one or more placards will not be “clearly visible” from the direction of the nearest transport vehicle or rail car, what then. The solution for the rail car is simple: 172.516(a) states that a placard’s visibility may be obstructed without a violation of the regulations if the cause of the obstruction is another rail car to which it is coupled. So, when coupled together, the front and rear facing placards on a rail car may be obstructed without a violation. Note however, that though obstructed from view, placards must still be present on each side and each end if required.
Compliance is trickier on the highway with its myriad of trucks and tractor-trailer combinations. The answer hinges on the definition of a transport vehicle, which is: ”a cargo-carrying vehicle such as an automobile, van, tractor, truck, semi-trailer, tank car or rail car used for the transportation of cargo by any mode” (LOI 09-0055 & 08-0098). A tractor-trailer combination fits the definition of two separate transport vehicles, whereas a straight truck is a single transport vehicle. Therefore, a placard on the front of a trailer in a tractor-trailer combination may be obstructed by the presence of the tractor or truck without violating 49 CFR 172.516(a) (LOI05-0063). Similarly, the front and rear facing placards on a trailer that is part of a multi-trailer load may be obstructed by the presence of additional trailers without a violation. However the front facing placard on a straight truck would be in violation of this part if it was not visible from the front. (LOI 04-0164).
If you wish for the front facing placard on a tractor-trailer combination to be visible to the front, you may mount the placard on the front of the tractor or rig. 49 CFR 172.516(b) allows for the front facing placard of a HazMat shipment to be affixed to the front of the truck-tractor instead of or in addition to the placarding of the front of the semi-trailer. This would also satisfy the requirements of 49 CFR 172.516(a). Note however, that if the tractor and trailer become separated, say if the HazMat shipment is stored incidental to transportation, then a front facing placard would be required for the trailer.
You may also be interested in this article on the General Display Requirements for Placards.
Compliance with the Hazardous Materials Regulations of the US DOT begins with training. I provide training for HazMat Employees as required by 49 CFR 172, Subpart H. I also provide RCRA Training for Hazardous Waste Personnel as required by 40 CFR 265.16. You may either attend one of my public/open enrollment training events or I can provide on-site training.
Please contact me for a free consultation of your training needs.
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.
The placarding requirements for the transportation of hazardous materials can be very confusing. Even during my years of driving a truck for Laidlaw Environmental Services I was often in doubt about placarding requirements. At my open enrollment training events I am frequently asked specific questions about placarding requirements where I must refer to 49 CFR 172, Subpart F for guidance. Additional questions arise when you must determine the placarding requirement for bulk packagings instead of transportation vehicles. 49 CFR 172.514 is the section of the regulations that deals specifically with the placarding requirements of bulk packages and is the subject of this article.
Right at the beginning – 49 CFR 172.514(a) to be exact – the regulations make clear that it is the responsibility of the shipper and not the carrier to affix (eg. stick, attach, or fasten) the required placards to a bulk packaging. This differs slightly from the placarding requirements for shipments of HazMat by highway found in 49 CFR 172.506which require the shipper to provide the required placards to the driver of a motor vehicle (ie, carrier), but not to affix them. More about the requirement of shippers to offer placards to a driver can be found here.
Unless an exception for your HazMat packaging is identified in the regulations (see below), it must be placarded on each side and each end – all four sides. If an exception exists for your bulk package you may use one of the following two options:
- Affix the applicable placards on two opposing sides only.
- Affix a HazMat Label on two opposite sides only per 49 CFR 172, Subpart E – specifically 49 CFR 172.406(e).
The excepted bulk packagings are as follows:
- A portable tank with a capacity of <1,000 gallons.
- A DOT 106 or 110 multi-unit tank car tank (railroad tank car designed to specifications).
- Another bulk packaging - such as a bulk bag or box – with a capacity <640 cubic feet. This does not include a portable tank, cargo tank, or tank car.
- An Intermediate Bulk Container or IBC as defined at 49 CFR 171.8. An IBC is also allowed the option of using smaller HazMat markings (proper shipping name and identification number) in place of the orange panel or placard. 49 CFR 172.302(b)(2) seems to allow for this option for a portable tank with a capacity <1,000 gallons, but this is not clear.
- A Large Packaging as defined in 49 CFR 171.8.
If a bulk packaging is not excepted and placarding is required, then the placards must remain even when it is empty unless it –
- Is sufficiently cleaned of residue and purged of vapors to remove any potential hazard.
- Is refilled with a different hazardous material to such an extent that the remaining residue is no longer hazardous.
- It contains the residue of a Class 9 hazardous substance below the reportable quantity and any markings, labels, or placards indicating it is hazardous are removed, obliterated, or securely covered in transportation [49 CFR 173.29(b)(1)].
You may read more here about the requirements for shipping empty packages of hazardous materials. You may also wish to learn much more about the Hazardous Material Regulations (HMR) of the US DOT and how they apply to you as a shipper of hazardous materials. While you’re at it you may also wish to learn more about your regulatory requirements under the US EPA as a generator of hazardous waste. I have two options for your consideration:
- Attend one of my open enrollment training events held nationwide and year round (see my schedule).
- Schedule on-site training for you and your employees for a flat fee of $1,749 and $10/trainee (contact me).
Whichever you choose you will meet the regulatory requirements of both the US EPA and the US DOT in one day.
As a Shipper of hazardous materials you may be unaware of your responsibility under 49 CFR 172.506 to provide placards to the driver of the motor vehicle for your shipment prior to its departure from your property. During the course of my RCRA Training and HazMat Training (combined in one 8-hour day for only $495!) I have found that many Shippers rely on the driver of the vehicle (ie. the Carrier) to provide the placards. In addition, they don’t maintain a supply of the necessary placards and would be unable to provide them if the driver requested them. A close reading of 49 CFR 172.506 is in order.
First, let’s be clear that it is your responsibility as a Shipper to provide to the driver the required placards for the material being offered for shipment. There is no specified time when placards must be provided (ie. when a placard threshold is met), but they must be provided before the shipment leaves your property and enters a public roadway. Again, if you offer hazardous materials for shipment by motor vehicle; then it is your responsibility to provide the required placards.
Therefore, you must be certain of the regulations pertaining to placard thresholds. The full regulations can be found at 49 CFR 172, Subpart F. However, the DOT Chart 14 provided by the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the US Department of Transportation will answer most of your questions. For most hazardous materials in non-bulk packaging (<119 gallons), the placarding threshold is ≥1,001 pounds. Research carefully though, because the threshold amounts may be a lot less for some hazardous materials and for bulk containers.
What if I offer the required placards for my shipment, but the driver declines the offer as he/she already has them? In that case – and only that case – you are off the hook and are not required to provide the placards. However, I suggest you make the offer for every hazardous material shipment, including hazardous waste. Don’t assume (as many do) that the driver has the required placards for your shipment. Speaking of hazardous waste, the US EPA regulations at 40 CFR 262.33 require a generator of hazardous waste to either placard the vehicle or offer placards to the initial transporter for their off-site shipments of hazardous waste.
A question that has come up at a few of my recent training events is this: What if I offer for shipment a hazardous material below the placard threshold – say, 500 pounds of a Class 3 flammable liquid (placard threshold ≥1,001 pounds) – but the driver already has 600 pounds of Class 3 flammable liquid on-board? My hazardous materials are below the threshold, but combined with the existing load is now an amount requiring placards. Must I provide the driver the required placards for this combined load? The answer is no. A close reading of 49 CFR 172.506(a)reveals that you need only provide the required placards for the material you are offering for shipment, not for the aggregate weight of all hazardous materials on the vehicle. Refer to 49 CFR 172.506(a)(1) which requires the driverto affix the required placards to the motor vehicle. In other words, you’re only on the hook to provide the required placards for what you offer for shipment. You may wish to provide placards to the driver even if it is not your responsibility however. Being right would be small solace if your shipment is refused due to a lack of the proper placards.
I suggest you make it part of your routine HazMat shipment procedure to ask the driver if he/she has the required placards and to provide them if necessary. Also, perform an inspection of the vehicle to ensure the required placards are in good condition, secure, and visible on all four sides of the vehicle before you sign the shipping paper or Uniform Hazardous Waste Manifest.
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.