In an earlier article I wrote about the requirements for placards to be visible when required for shipments of hazardous materials. Those regulations [49 CFR 172.516(a,b)] will impact where you mount HazMat placards on a bulk packaging or motor vehicle. Also important are the regulations to ensure and maintain the visibility of those placards once affixed. 49 CFR 172.516(c-e) addresses those requirements.
Each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device must be:
- Securely attached or placed in a holder (Appendix C to this part contains recommendations for placard holders). Watch out for adhesive-backed placards or those attached with tape. Will the adhesive hold up for the length of the shipment?
- Located clear of appurtenances and devices: ladders, pipes, doors, and tarpaulins. Note that the locations of these appurtenances and devices, such as a tarp, may change after the placard holders have been affixed, thus putting you into non-compliance.
- So far as practicable, located so that dirt and water from the wheels are not directed to it. This means that routine inspections of placards must take place in all seasons.
- Located away from any marking (such as advertising) that could substantially reduce its effectiveness in communicating the potential hazards of the hazardous material. Placards must be at least three inches away from any such marking.
- Attached in a way that the words or identification number, if required, are displayed horizontally, reading from left to right. I have seen violations of this requirement particularly when temporary or adhesive placards are used.
- Maintained by the carrier so that the effects of weather, damage, etc. do not substantially reduce the effectiveness of the placards color, format, legibility, and visibility. Colors fade over time, so be prepared to periodically replace your placards.
- Affixed to a background of contrasting color, or must have a dotted or solid line outer border which contrasts with the background color. Note that HazMat placard design and color may be changed by regulation over time (new v. old organic peroxide placard). This may require you to move placards to a new location if your background of contrasting color is no longer present.
- The recommended specifications for a placard holder are found in Appendix C to 49 CFR 172, Subpart F. However, if you choose not to follow these recommendations, the means used to attach a placard may not obscure any part of its surface other than the borders. This is big. Ensure that your placard holders either follow the recommendations of Appendix C, or they only hold the placard in place by its borders. The hinged form of the placards is acceptable provided all of the above requirements are met.
These regulations apply primarily to the carrier of a hazardous material and the motor vehicle, but the bullet points above also apply to a bulk packaging, freight container or aircraft unit load device. After reviewing this information and the applicable regulations, take the time to inspect your placards and the means to affix them. Make sure you are in compliance with these regulations or take the necessary steps to return to compliance.
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.