When required on transport vehicles or freight containers (defined below), identification numbers for hazardous materials (found in Column 4 of the Hazardous Materials Table) must be displayed in one of three ways as detailed in 49 CFR 172.336. The allowable methods for display of identification numbers are as follows:
- On orange panels with the specifications as detailed in §172.332(b),
- On a plain white square-on-point display configuration that has the same outside dimensions as a placard: 250 mm (9.84 inches) on a side, or;
- On a placard in conformance with the requirements of §172.332(c).
If a situation arises where both placards and the identification number are required but the display of the identification on the placard is prohibited per §172.334(a), then the identification number must be displayed on an orange panel or the plain white square-on-point display configuration. Both must be displayed in association (i.e. next to) the required placard.
Definitions used in this article:
Transport vehicle means a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, rail car, etc.) is a separate transport vehicle.
Freight container means a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.
So, a question: Is the display of the identification number in this photo in compliance with the Hazardous Material Regulations (HMR) of the PHMSA/USDOT?
The answer is yes. The identification number seen in the photo (3082) applies to a Hazard Class 9 liquid. Not having seen inside the truck, I will assume that it contains a bulk packaging (>119 gallons for a liquid) of a Class 9. The transportation of a Class 9 in a bulk package inside a transport vehicle mandates the display of the identification number on all four sides of the vehicle. The HMR do not, however, require the use of the Class 9 placard for domestic transportation (read my article to learn why a Class 9 placard is not required for domestic transportation). In this case the carrier has opted to display the identification number on his vehicle without the Class 9 placard.
Something like this may catch your eye on the highway (it did mine, anyway) and cause you to wonder how it can be so. A review of the regulations reveals the reason why. Take the time to attend one of my Training Webinars and you’ll learn about the HazMat transportation regulations of the PHMSA/USDOT.