Question to the Contact Me page of my website on March 7, 2015:
Looking for guidance on the shippers responsibilities in reference to DOT hazmat regs when shipping empty 6,000 fuel tank trailers. The tank trailers have been re-built, pump tested, drained (but not triple rinsed), contain residual diesel fuel (50 gal or less) and will be loaded on another conveyance/trailer for transport (will not be towed).
My “Thanks and give me some time” response on March 9th:
That’s a good question. Let me do a little research and get back to you sometime later this week.
Questioner’s acknowledgement and a little more information (3.9.15):
Thank you Daniel.
We are being told the trailers must have a drain and purge certificate (be purged and triple rinsed) and hazmat certification documents prepared prior to shipment; however purging with water causes problems with the functionality of the tanker if it sets in storage for a while before shipment. The trailers are drained but there is residual diesel remaining in the pump filters, etc.
The Big Answer on March 13th:
What you describe (a 6,000 gal fuel tank trailer) is identified in the Hazardous Material Regulations (HMR) of PHMSA/USDOT as a Cargo Tank. From 49 CFR 171.8:
Cargo tank means a bulk packaging that:
(1) Is a tank intended primarily for the carriage of liquids or gases and includes appurtenances, reinforcements, fittings, and closures (for the definition of a tank, see 49 CFR 178.320, 178.337-1, or 178.338-1, as applicable);
(2) Is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment to a motor vehicle is loaded or unloaded without being removed from the motor vehicle; and
(3) Is not fabricated under a specification for cylinders, intermediate bulk containers, multi-unit tank car tanks, portable tanks, or tank cars.
When a Cargo Tank is part of a motor vehicle it is identified as a Cargo Tank Motor Vehicle. Also from 49 CFR 171.8:
Cargo tank motor vehicle means a motor vehicle with one or more cargo tanks permanently attached to or forming an integral part of the motor vehicle.
So, what you describe is the transportation of a Cargo Tank that contains the residue of a hazardous material (I assume the diesel fuel is a Class 3 Flammable or Combustible Liquid). The HMR regulates a packaging containing any residue of a hazardous material the same as if it was full. There is an exception from some of the requirements of the HMR available to packaging with HazMat residue, but it does not apply to a bulk packaging as in this situation.
- Transport the HazMat residue-containing Cargo Tanks as hazardous materials subject to all of the requirements of the HMR. This includes shipping papers, placards, HazMat labels, markings, HazMat Employee training, registration as a Shipper of HazMat, providing emergency information, &etc.
- Remove all residue from the Cargo Tanks so that they are rinsed, cleaned, and purged of all vapors. Then ship as non-hazardous.
- Fill the Cargo Tanks with some non-hazardous material that is compatible with the residual diesel fuel so that the resulting mixture is non-hazardous.
Another grateful HazMat Shipper (though not yet a customer) on March 13th:
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I receive and respond to questions like this all the time. Let me help you with the questions you have about the transportation of hazardous materials.