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.
NOTE: This document is for general guidance only and should not be used to determine compliance with 49 CFR, Parts 100-185
Right on page 1 the PHMSA makes clear that this is a guidance document and is no substitute for the regulations. Helpfully, throughout the DOT Chart 15 you can find references to the applicable section of the HMR. Want to know more about the OVERPACK marking? 40 CFR 173.25(a)(4). Curious about the display of identification numbers on a motor vehicle in association with placards? 40 CFR 172.332.
The bottom 1/3 of page 1 identifies several Markings both by image and the regulatory citation. Here a difference from the DOT Chart 14 becomes apparent. Whereas the DOT Chart 14 displayed both the ORM-D and ORM-D AIR marking, the DOT Chart 15 only shows the ORM-D. The DOT Chart 15 also includes the new Limited Quantity markings (one for air and one for all other modes) and the old – but still acceptable – Limited Quantity marking. For a full explanation of all this, please read my article: Authorization for use of the Consumer Commodity Classification (ORM-D) Extended to end of 2020!
Page 2 is dedicated entirely to the applicable HazMat Labels for each of the nine hazard classes. For ease of understanding compliance requirements, some non-HazMat Labels are included on page 2, such as:
- The OSHA Biohazard marking [29 CFR 1910.1030(g)].
- The CDC Etiologic Agent label (42 CFR 72.3 & 72.6).
Updates from the DOT Chart 14 on page 2 of the DOT Chart 15 include:
- The new Cargo Aircraft Only HazMat label.
- The new Organic Peroxide (Hazard Class 5, Division 5.2) HazMat label.
Page 3 of the new DOT Chart 15 displays images and threshold determination information for the placards of the nine hazard classes plus the Dangerous placard. Slightly out of place here is the Limited Quantity marking which is required for vessel transport only of a Limited Quantity. Helpful information on page 3 includes:
- Placarding options for Class 3 Flammable and Combustible Liquids: Gasoline and Fuel Oil.
- A summary of the correct usage of the Dangerous placard.
- Confirmation that the Class 9 placard is not required for domestic transportation of a HazMat.
Updates from the DOT Chart 14 to the DOT Chart 15 found on page 3 include:
- The Organic Peroxide placard (in the process of being phased in).
Note: Though at first glance they may appear to be exactly the same – other than size – take a close look and you will see that many placards and HazMat labels differ slightly in their appearance.
Page 4 of the new DOT Chart 15 contains even more helpful information for anyone in the regulated community of HazMat transportation:
- General Guidelines on the use of Warning Labels and Placards.
- The Table 1 & 2 Placarding Tables [§172.504(e)]. As the name implies, these table are vital when determining the necessary placards for a shipment of HazMat.
- Guidance on the use of identification numbers as a marking in association with placards on a motor vehicle.
As you can see the DOT Chart 15 is a great tool for anyone who works with the Hazardous Material Regulations of the USDOT/PHMSA. And that’s why I always include it as a hand-out in my HazMat Employee training. At a minimum I recommend easy access to the DOT Chart 15 for the following:
- HazMat Employee training providers.
- Shipping and Receiving managers if they handle HazMat.
- Truck drivers who transport any quantity of HazMat.
- Shipping and Receiving personnel if they handle HazMat.
And how can you get access to the DOT Chart 15? Well, you don’t have to pay a lot since the USDOT/PHMSA wishes to make it available to the regulated community. Options include:
- Attend my training (Public Seminar or Onsite). All attendees to my training receive a glossy four page DOT Chart 15 to take with them at its conclusion.
- Download and/or print right from the PHMSA website: DOT Chart 15. Use care when exercising this option. You must be certain your printer will provide the color and clarity necessary to properly communicate the information.
- Purchase a glossy or laminated version from a commercial supplier. I used to do this, but I don’t recommend it anymore since you are able to…
- Purchase directly from the PHMSA online for a pittance of what a commercial supplier will charge you. Refer to Publications for Sale on the PHMSA website.
The DOT Chart 15, just like a lot of guidance documents from the PHMSA, is a great source of information, but just that: information. It can’t, nor should it, substitute for the HazMat Employee training that is required by the USDOT/PHMSA at 49 CFR 172, Subpart H. Be sure to contact me if you have any questions about the DOT Chart 15, the HMR, markings, placards, HazMat labels, shipping papers, or anything else to do with the transportation of hazardous materials.