Daniels Training Services

Q&A: Is a Shipping Paper Required for the Transport of Diesel Fuel in a 1,000 Gallon Cargo Tank?

Q&A: Is a Shipping Paper Required for the Transport of Diesel Fuel in a 1,000 Gallon Cargo Tank?

HERE IS A QUESTION I RECEIVED THROUGH THE CONTACT ME PAGE OF MY WEBSITE.

Names and references to locations and companies have been changed to preserve anonymity.  Other minor editing changes have been made as well.

Subject: Help
Message: Hi Daniel,
My name is <<John Smith>> and I work for a construction company in a <<U.S. State>>. I drive a fuel/lube truck with a 1000 gallon diesel tank. I also haul engine, transmission, coolant, slop oil, and grease that are 100 gallons or less. I fuel off road construction equipment to our sites. My company does not or should I say certain individuals in the company do not know about HazMat DOT regulations.
What kind of shipping paper do I need? Would I need a permanent for diesel only or do I need to have the other chemicals listed as well?
I am personally getting the items I need from a well known company in this field. I purchased the orange book, placards 1993, and another HazMat book. I believe the company needs to have the HazMat Registration Permit also right. Please help. It seems I am alone with people who don’t know or don’t care. Call me, ###-###-####, so we can discuss this and perhaps if the price is right I would take one of your courses.
Respectfully for the cause,

AND HERE IS MY RESPONSE:

Thanks for contacting me. I’ll do my best to answer your questions.

First of all, diesel in the quantity and bulk packaging you describe is a hazardous material subject to the regulations of the USDOT when transported in commerce. Therefore, the following is required (at a minimum):

  • A shipping paper that describes the hazardous material (diesel) and any others you transport. A permanent diesel shipping paper would work as long as it is handled properly.
  • Placards on all four sides of the vehicle.
  • Markings on all fours sides of the vehicle: 1993, “Diesel”, or “Combustible”.
  • Emergency response information immediately available to the driver. The 2012 ERG is good for this. You must also have a 24 hour emergency response phone number.
  • The vehicle is a Commercial Motor Vehicle, subject to regulations for its operation on the highway. Depending on its weight, the driver may require a Commercial Driver’s License and be subject to hours-of-operation limits, &etc.
  • A placarded quantity of HazMat requires registration with the USDOT and payment of the fee.
  • Anyone involved in the transportation of the HazMat (not just the driver) must receive initial and triennial (every 3 years) HazMat Employee Training. Drivers require an additional component to HazMat Employee Training to include operation of the vehicle.

The other materials you mention may not be hazardous materials (or they might!). It is up to the Shipper to determine if a material is hazardous or not and therefore subject to the regulations.

You are right to be concerned about compliance issues at your company. I’d be happy to answer any other questions you may have.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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