Q&A: Is stoddard solvent a marine pollutant?

Note: this group allows its members to post questions like this one and then hope for answers from others within the group. What follows are some of those answers with mine at the end.

First to answer…

Stoddard Solvent is Mineral Spirits. UN 1268, PETROLEUM DISTILLATES , N.O.S. (Naphtha solvent), 3, PG III, combustible liquid

And…

Check the SDS for that product

And then me:

I will try to answer your question. Please see below.

General information:

White spirit or mineral spirits, also known as mineral turpentine, turpentine substitute, petroleum spirits, solvent naphtha, Varsol, Stoddard solvent, or, generically, “paint thinner”.

USDOT/PHMSA:

To be a marine pollutant per USDOT/PHMSA regulations it must be each of the following:
- Identified by name as a marine pollutants (appendix B to Hazardous Materials Table at 49 CFR 172.101).
- 10% or more in solution if marine pollutant. 1% or more in solution if a severe marine pollutant (identified by ‘PP’ in column 1 of list).
- Transported in any size packaging by vessel or transported in a bulk packaging by highway, rail, or air.
White Spirit, low (15-20%) aromatic is identified by name as a marine pollutant.
Turpentine is identified by name as a marine pollutant.
Read: What is a Marine Pollutant?

It is impossible to determine if your product is a marine pollutant per USDOT/PHMSA regulations without first identifying exactly what it is and its concentration, packaging, and mode of transport.

IMO:

To be a marine pollutant per the IMO dangerous goods code (IMDG), it must be one of the following:
- Display a ‘P’ in the ‘MP’ column for its entry in the Index.
- Display a ‘P’ in column 4 of the Dangerous Goods List (DGL) for its entry.
- Meet the criteria of the UN Recommendations (2.9.3) for an Environmentally Hazardous Substance (aquatic environment).
If identified as a marine pollutant in either the Index or the DGL it is not subject to regulation as a marine pollutant if it does not meet the UN criteria.
If not identified as a marine pollutant in either the Index or the DGL it is subject to regulation as a marine pollutant if it is proven to meet the UN criteria.
White Spirit, low (15-20%) aromatic, white spirit, & TURPENTINE are all identified as a marine pollutant in the Index.

Unless the shipper has data to indicate it does not meet the criteria for an environmentally hazardous substance (aquatic environment), then the above identified substances must be shipped as a marine pollutant when subject to the IMDG Code.

And…

49 CFR 172.101, Appendix B (4): if not listed as a marine pollutant but meets criteria for marine pollutant per IMDG, then may be transported as marine pollutant within U.S.
49 CFR 172.101, Appendix B (5): if listed as a marine pollutant but does not meet criteria for marine pollutant per IMDG, then may be excepted from transport as marine pollutant within U.S. with approval from PHMSA/USDOT.
The International Air Transport Association (IATA) uses the same UN criteria as the IMO for classifying a marine pollutant.

More information:

I hope this helps.

Please contact me with any other questions.

If you like this article, please share it using any of the social media platforms identified at the bottom of this article.

You’ll look real smart recommending my articles!

Conclusion:

The classification of a marine pollutant is complicated. It is made more so by the fact that the classification of a marine pollutant of USDOT/PHMSA within the U.S. differs from the international regulations of IATA & IMO. That means the requirements for transport of a HazMat within the U.S. may differ from those outside of the U.S. Make certain you determine the applicable regulations and them comply with them.

General Provisions for Cargo Transport Units

A person who offers a hazardous material (HazMat) for transport to, from, or through the U.S. must comply with the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). If a person offers for transport a dangerous good (dangerous good is the term used by international regulations to refer to what we in the U.S. call a hazardous material) for transport by vessel in international waters that person must also comply with the International Maritime Organization (IMO) and its Dangerous Goods Code (IMDG Code).

The challenge for a shipper is knowing when to comply with the HMR and when compliance with the IMDG Code is required. To summarize the requirements: a shipper may comply with the IMDG Code – even for transport within the U.S. if all requirements of the IMDG Code are met and the shipper complies with 49 CFR 171.22 and §171.25.

The purpose of this article is to explain the general provisions for use of cargo transport units (CTUs) to transport dangerous goods by vessel in compliance with Chapter 7.3.2 of the IMDG Code.

Before we begin…

This article is based on the 2018 edition of the IMDG Code containing amendments 39-18. This edition alone must be used to determine compliance in 2020 but is optional for use in 2019. The 2016 edition, which includes amendments 38-16, is also optional for use in 2019. It alone was mandatory in 2018. Confused? Read: The IMDG Code Amendment Cycle.

For the purposes of this article it doesn’t matter which edition is used. The effective regulations are unchanged between the two.

: 2018 Edition of the IMDG Code

: 2016 Edition of the IMDG Code

Scope:

The regulations of Chapter 7.3 of the IMDG Code apply to those persons responsible for the loading of the CTU. This may be the shipper, a freight-forwarder, the motor carrier responsible for highway transport, or shore-based personnel at the port of departure; it does not have to be the person identified as the shipper on the Dangerous Goods Transport Document.

A cargo transport unit is defined at 1.2.1 of the IMDG Code.

Cargo transport unit means a road transport tank or freight vehicle, a railway transport tank or freight wagon, a multimodal freight container or portable tank, or an MEGC.

For the purposes of this article think of a CTU as a big metal box used to contain packagings of dangerous goods.

General Provisions for Cargo Transport Units:

By their very nature “General Provisions” don’t get into specifics – that’s saved for later.

CTU must be “strong enough to withstand the shocks and loadings normally encountered during transport”. This requires a knowledge of the conditions to be expected during the anticipated journey.
CTU must be constructed so as to prevent the loss of the contents.
Where appropriate, CTU must have devices that will assist in the securing and handling of the dangerous goods it contains. In other words, whatever devices are necessary to secure the dangerous goods within the CTU must be available.
CTU must be adequately maintained.
If the CTU is a “container” per the International Convention for Safe Containers (CSC) 1972, then the applicable provisions of the CSC must be followed. However, the CSC does not apply to offshore containers handled in open seas. Those must meet requirements established by the competent authority (USDOT/PHMSA in the U.S.) An offshore container designed to be handled in open seas shall be clearly marked: “OFFSHORE CONTAINER” on the safety approval plate.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

In my next article I’ll address the Packing of Cargo Transport Units

Conclusion:

Pretty simple and pretty vague. Remember, compliance with chapter 7.3.2 is the responsibility of the person(s) who load the cargo transport unit with dangerous goods to be transported by vessel. If this is you, make certain all personnel are knowledgeable not only of these regulations but all of the IMDG Code applicable to their job – which includes training.

Packing of Cargo Transport Units for Transport by Vessel per the IMDG Code

The purpose of this article is to explain the requirements for the loading of cargo transport units (CTUs) for transport by vessel in compliance with Chapter 7.3.3 of the IMDG Code.

Before we begin…

For the purposes of this article it doesn’t matter which edition is used. The effective regulations are unchanged between the two.

: 2016 Edition of the IMDG Code

: 2018 Edition of the IMDG Code

Scope:

A cargo transport unit is defined at 1.2.1 of the IMDG Code.

Cargo transport unit means a road transport tank or freight vehicle, a railway transport tank or freight wagon, a multimodal freight container or portable tank, or an MEGC.

For the purposes of this article think of a CTU as a big metal box used to contain packagings of dangerous goods.

The general provisions for cargo transport units were addressed in an earlier article

Packing of Cargo Transport Units:

CTU must be checked prior to use to ensure it is fit for intended purpose.
Interior and exterior of CTU must be inspected prior to loading to ensure their is no damage that could affect its integrity or that of the packages it is to contain.
Condition of packages.
- Packages must be examined before loading. Packages shall not be loaded in CTU if found to be damaged, leaking, or sifting.
- Excessive water, snow, ice or foreign matter adhering to packages must be removed before packing into CTU.
- If handling provision “keep as dry as reasonably practicable” (H1) is assigned in column 16a of the Dangerous Goods List for a dangerous good to be loaded in a CTU, then the CTU must be kept as dry as reasonably practicable.
Drums of dangerous goods loaded in a CTU must always be stowed in an upright postion unless otherwise authorized by the competent authority (USDOT/PHMSA in U.S.).
More on packages.
- CTU must be loaded in compliance with 7.3.4 Segregation provisions within cargo transport units. Incompatible dangerous goods – or other non-dangerous goods must be segregated.
- Specific loading instructions such as: orientation arrows, not to be double stacked, keep dry or temperature control requirements shall be met.
- Liquid dangerous goods must be loaded below dry dangerous goods whenever possible.
Securing and restraining packages within CTUs.
- Packaged dangerous goods and unpackaged dangerous articles must be secured within the CTU to prevent any movement during transport that would change their orientation or cause them to be damaged.
- Methods of restraint may include: fastening straps, sliding slatboards, adjustable brackets, and filling any voids by the use of dunnage or by blocking and bracing.
- If dangerous goods are transported in the CTU with other goods (e.g., heavy machinery or crates), all goods must be secured to prevent the release of dangerous goods.
- If restraints such as banding or straps are used they must not be over-tightened to cause damage or deformation of the package or the securing points (such as D-rings) within the CTU.
- Packages must be packed to minimize the likelihood of damage to fittings during transport. Fittings on packages must be adequately protected.
- If restraints such as banding or straps with integral container fittings are used, packer must use care to ensure the Maximum Securing Load (MSL) of the fittings is not exceeded.

Like this article?

No marketing emails!

Stacking of packages.
- Packages must not be stacked unless designed for stacking.
- Exercise caution when stacking packages of different stacking designs.
- Load bearing devices must be used to prevent a stacked package from damaging the package below.
Cargo shall be entirely contained within the CTU without overhang or projections. However, oversized machinery (e.g., tractors and vehicles) may overhang or project outside of the CTU if the dangerous goods within the machinery cannot leak or spill outside of the CTU.
Care must be taken during preparation for transport and loading of packages to prevent damage. Damaged or leaking packages shall not be transported.
If dangerous and non-dangerous goods are packed in the same CTU, dangerous goods should, whenever possible, be packed near the doors with marks and labels visible.
If the doors of a CTU are locked it shall be possible to open them without delay in an emergency.
When venting of the CTU is required venting devices shall be kept clear and operable.
CTUs containing any amount of a dangerous good shall be marked and placarded per chapter 5.3 of the IMDG Code.
Irrelevant marks, labels, placards, orange panels, signs and marine pollutant marks shall be removed, masked or removed before packing a CTU.
CTU shall be packed so that cargo (includes non-dangerous goods) is uniformly distributed consistent with the CTU Code.
If the CTU is packed with Class 1 Explosives, it must be “closed” as defined at 7.1.2 of the IMDG Code.
If the CTU is packed with Class 7 Radioactive, the transport index and, if applicable, the criticality safety index, shall be limited according to 7.1.4.5.3 of the IMDG Code.
The person(s) responsible for packing dangerous goods in a CTU shall provide a “container/vehicle packing certificate” per 5.4.2 of the IMDG Code. This document is not required for tanks.
Flexible bulk containers are not allowed to be transported in CTUs per 4.3.4 of the IMDG Code.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Conclusion:

Sometimes the regulations defy any attempts at summation and simplification and I wind up listing them almost verbatim; that is the case here. Remember, compliance with chapter 7.3.3 is the responsibility of the person(s) who load the cargo transport unit with dangerous goods to be transported by vessel. If this is you, make certain all persons receive initial and triennial training as required by the USDOT/PHMSA and the IMDG Code.

Q&A: May I transport small quantities (car batteries & compressed nitrogen) by highway?

A question from somewhere in the U.S. (October 23, 2017):

Hi my name is <<name>>. I drive a box truck for work. We have two facilities. I transport materials back and forth. I carry minimum hazmat from time to time. What are the requirements for transporting say 6 car batteries. Or a very small bottle of compressed nitrogen?. Do they need to be boxed up with placard on packaging and the proper emergency contact info on the outside of the box and should I have a b.o.l. for transportation with ads sheets. If you can help me I’d be so grateful. I’ve been back and forth with my concerns to the company and they basically ignore me.

Sincerely

My reply that day:

I believe I can answer your question. Please see below:

It sounds like what you are describing is the transport of hazardous materials (HazMat) by a private motor carrier.
This type of transport is not subject to full USDOT regulation if transported according to the Materials of Trade Exception.
The cylinder of nitrogen is acceptable as long as its weight is no more than 100 kg.
Car batteries should be OK as long as each weighs no more than 30 kg.
Total HazMat on vehicle no more than 200 kg.
If in compliance with the above, only basic precautions need to be taken to secure the load, ID the HazMat, and inform the driver.
Also, the batteries alone may be transported under an exception from regulation found at 49 CFR 173.159(e) which is part of this article: Packaging Wet Batteries for Transportation

Interested in a Webinar that covers this topic, and more!

My Webinar Training Schedule

I hope this helps.

Please contact me with any other questions.

FAQ: What are the Penalties for non-Compliance with the USDOT Regulations in 2019?

Like any decent regulatory agency the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) issues monetary penalties for violations of its Hazardous Materials Regulations (HMR). And wouldn’t you know it, USDOT/PHMSA adjusts those penalties to keep pace with inflation. Below are the increased penalty amounts for 2019:

Note: all penalties are assessed per violation, per day.

Maximum civil penalty for a violation of the HMR: $78,976. An increase from $78,376 in 2018.
If the violation results in death, serious illness, severe injury, or substantial property damage: $186,610. An increase from $182,887 in 2018.
The minimum penalty for a violation related to HazMat Employee training: $481. An increase for $10 from $471 in 2018.

Remember, those amounts can be assessed separately for each day that each violation exists.

I’m sure you’ve been in a situation where someone has told you that the company can’t afford HazMat Employee training. Looking at the above amounts I’d say it’s more correct to say the company can’t afford not to have HazMat Employee training.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Q&A: What are the regulations for shipping a combustible liquid (paint) from U.S. to Canada?

An email query on October 20, 2017:

Hello,

Just read your article “US DOT Exception for Combustible Liquid Hazardous Materials” and it was very helpful to my company.

One question… can this combustible exemption be used when shipping to Canada?

My reply:

I will be able to assist you with this issue. A few questions:

What is the mode of transport? Air, vessel, highway, or rail?
What is the flash point? <100 degrees F? 100 – 140 degrees F? >140 degrees F?
Will the packaging be bulk: cargo tank, portable tank, IBC? Or, non-bulk: 55-gallon drum or smaller?

Thank you and please advise.

Looks like I didn’t move fast enough!:

Daniel,

Thank you so much for your quick response.

In the past half hour, I was able to speak with someone in Canadian “DOT” who was able to help answer all of my questions.

Thanks again for your response but they were able to straighten me out,

Like this article?

No marketing emails!

But I’m a curious guy, always wanting to learn more:

Your welcome.

If you don’t mind taking the time, could you please confirm my initial determination (more research was planned) that a form of the U.S. combustible liquid exception is available in Canada if transport is by highway or rail?

My curiosity was rewarded:

Hello Daniel,

This is the response that I received from Transport Canada.

Makes sense to me!

Thanks again,

TEXT OF LETTER FROM TRANSPORT DANGEROUS GOODS (TDG) CANADA FOLLOWS:

Mr. <<>>

Flammable liquids in PG III are not regulated in Canada as a dangerous good if the flash point is above 37.8 C (~100 °F), they are exempt from shipping papers, labels, packaging, training, emergency response planning, by road under 1.33 as follows:

1.33 Class 3, Flammable Liquids: General Exemption

SOR/2008-34

Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks), Part 5 (Means of Containment), Part 6 (Training), Part 7 (Emergency Response Assistance Plan), Part 9 (Road) and Part 10 (Rail) do not apply to the handling, offering for transport or transporting of dangerous goods included in Class 3, Flammable Liquids, on a road vehicle, a railway vehicle or a ship on a domestic voyage if the dangerous goods

(a) have no subsidiary class;

(b) are included in Packing Group III and have a flash point greater than 37.8°C; and

(c) are in one or more small means of containment designed, constructed, filled, closed, secured and maintained so that under normal conditions of transport, including handling, there will be no accidental release of the dangerous goods that could endanger public safety.

In addition Part 9 of the regulations allows for reciprocity with US DOT requirements under 49 CFR to destination from USA to Canada IAW 49 CFR.

So, in short, yes you may ship as stated to destination in Canada.

Regards

D.W. (Dave) Greyeyes

Transport Dangerous Goods Inspector

Prairie and Northern Region – Surface

Transport Canada / Government of Canada

Room 305 101-22^nd Street East, Saskatoon, SK., S7K 2L2

David.greyeyes@tc.gc.ca / Tel : 306 975 6246 / Fax: 306 975 4555 / TTY: 1.888.675.6863

TEXT OF LETTER TO TRANSPORT DANGEROUS GOODS (TDG) CANADA FOLLOWS:

Good Morning Sir/Madame,

I have a question about shipping combustible paint to Canada. Our company is located in USA.

The paint that we are shipping to Canada has a flash point of 108 degree F (42 degrees C). From what I understand, this classifies it as a combustible material in Canada.

Here in the US, combustible materials do not need any classification or labelling as they are exempt under US DOT laws.

Can I ship into Canada without labelling/hazardous documentation (same laws as in the US)?

Thanks very much for your time in this matter,

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Conclusion:

So there you have it, right from our neighbors to the north! The combustible liquid exception found in USDOT/PHMSA regulations is valid in Canada as well.

Q&A: Is the entire name of the receiving facility required on the uniform hazardous waste manifest?

A question from my website (October 10, 2017):

Do i need to print the entire name of a waste receiving facility as permitted, or can I abbreviate it?

My reply that same day:

Thank you for contacting me. I will try to answer your question below:

The USEPA instructions for completing the Uniform Hazardous Waste Manifest include the following:

Item 8. Designated Facility Name, Site Address, and U.S. EPA ID Number
Enter the company name and site address of the facility designated to receive the waste listed on this manifest. Also enter the facility’s phone number and the U.S. EPA twelve digit identification number of the facility.

There is nothing that I can find in EPA regulations that prohibits the abbreviation of the designated facility. Nor is it specifically allowed.
USDOT regulations at 49 CFR 172.201(a)(3) prohibit the use of abbreviations in the shipping description unless specifically authorized by regulations. However, the designated facility is not part of the shipping description.
State regulations may be more strict than those of the USEPA and may contain a prohibition on the use of abbreviations, though I doubt it. You may wish to check with the state of both the generator and designated facility.

Like this article?

User fees as of November 9, 2018:

No marketing emails!

In sum: I don’t recommend abbreviating information on the Uniform Hazardous Waste Manifest but cannot find anything in the regulations – either USDOT or USEPA – that specifically prohibits it.

I hope this helps. Please don’t hesitate to contact me with any other questions.

At that seemed to do it because I didn’t hear anymore from him.

While I prefer to give clear answers based on precise language of the regulations, sometimes that isn’t possible. As in this instance, the regulations don’t always address every possible circumstance. In those situations I think it best to be conservative and play it safe.

FAQ: May I continue to use paper manifests after the launch of the e-Manifest System on June 30, 2018?

The activation of the e-Manifest System by USEPA on June 30, 2018 caught some hazardous waste handlers by surprise. Since the system’s launch USEPA has worked diligently to fix its few small bugs, provide regulatory relief where it must, and answer questions from the hazardous waste handlers (e.g. generators, transporters, receiving facilities or designated facility, state regulatory agencies, & brokers) who are trying to use it. Here is one of those questions.

Some background:

The e-Manifest System was created by the U.S. Environmental Protection Agency (USEPA) to allow for an entirely paperless method to track the progress of a regulated waste shipment from “cradle-to-grave” (read: Use of the e-Manifest and: History of the e-Manifest). At its core is the creation and supported use of an electronic version of the uniform hazardous waste manifest, the e-Manifest System. The system may be used for the transport in commerce of any waste that is required to use the uniform hazardous waste manifest under Federal or state regulations. This includes:

Hazardous waste generated by a large quantity generator or small quantity generator.
PCB waste subject to regulation under the Toxic Substances Control Act (TSCA).
Waste subject to state regulation, e.g., Non-RCRA Hazardous Waste in California and Class 1 Non-Hazardous Industrial Solid Waste in Texas.

Not sure of your hazardous waste generator status? Take this short survey

So, the answer to that question:

Yes. USEPA regulations allow regulated waste handlers to continue using paper manifests after the system launch on June 30, 2018. However, this continued use comes with some modifications to current practice and a cost($)!

Modifications???

The regulations of the e-Manifest System mandated changes to the paper manifest form after June 30, 2018.

Replacement of the 6-part (or page) manifest with a 5-part form. The two parts previously detailed to the state (parts 1 & 2) have been replaced with one (part 1) to be submitted to the e-Manifest System. The copy notation at the bottom of part 1 will state this as a directive.
A notice at the bottom of part 3 advising destination facilities to review their responsibilities (printed on the back) under the e-Manifest System if they receive a paper manifest.
New instructions on the back corresponding to each type of waste handler (generator, transporter, designated facility) and their responsibilities under the e-Manifest System.

If the new 5-part manifest form is used, no problem. Just follow the instructions. But, if waste handlers continue to use the 6-part manifest after June 30, 2018 (to deplete existing stocks) the directive text at the bottom of part 1 must be covered with a sticker that reads: “designated facility to EPA’s e-Manifest system” and part 2 discarded.

If you like this article, please share it using any of the social media platforms identified at the bottom of this article.

You’ll look real smart recommending my articles!

Cost???

While it does not currently mandate the use of the e-Manifest System USEPA has its ways to encourage waste handlers to transition from paper to electronic: money. Persons who continue to use the paper manifest after June 30, 2018 will pay higher fees for each manifest. This fee is paid by the designated facility who must submit the manifest to the system but I’m sure they will pass those costs on to the generator.

Mailed in paper manifest: $15.00
Scanned image upload: $10.00
Data+ image upload: $6.50
Electronic manifest (fully electronic and hybrid): $5.00

The future:

Beginning on June 30, 2021, USEPA will no longer allow the designated facility to mail paper manifest for processing into the e-Manifest System. This does not prevent the continued use of paper manifests but it will require the designated facility to be able to scan and upload the paper manifest in order for the shipment to be tracked in the e-Manifest System.

According to USEPA, “In several years…” it will evaluate e-manifest user trends and consult with the e-Manifest system Advisory Board to determine if additional restrictions should be adopted on the use of paper manifests. Again, from USEPA:

However, this will not have any impact on users for at least the initial five years of program implementation.

So that means you have until, at least, 2023 before you may have to abandon the paper manifest entirely.

Confused? Contact me with questions.

Daniels Training Services, Inc.

815.821.1550

Also, help is available from USEPA: Questions About the e-Manifest System

And remember, if the e-Manifest System concerns you and the operations of your facility, you are likely subject to regulation that requires training for your hazardous waste personnel. I can help with that as well!

Q&A: Do I have to placard the vehicle if placards are visible on IBCs?

A question (09.22.17):

if you are carrying 2 – totes of sulfuric acid on flatbed rail side truck and the totes are placarded correctly with the un# bulk placards. Does the truck also have to be placarded with the same placards?

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

My answer:

The answer to your question is yes, the truck must display the required placards in addition to those on the totes if by “tote” you mean an intermediate bulk container or IBC and not a portable tank as your subject line indicates. Please see below.

49 CFR 172.504(a) requires a transport vehicle to display placards on all four sides (i.e. each side and each end) unless the type and quantity of HazMat is excepted from placarding requirements. This is not the case in your scenario.
49 CFR 172.516(a) requires the placards on a vehicle to be clearly visible and allows the required display of placards to be replaced by their display on a freight container or portable tank. An IBC is not indicated as an option for this exception.
49 CFR 171.8 defines a freight container: 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.
49 CFR 171.8 defines a portable tank: Portable tank means a bulk packaging (except a cylinder having a water capacity of 1000 pounds or less) designed primarily to be loaded onto, or on, or temporarily attached to a transport vehicle or ship and equipped with skids, mountings, or accessories to facilitate handling of the tank by mechanical means. It does not include a cargo tank, tank car, multi-unit tank car tank, or trailer carrying 3AX, 3AAX, or 3T cylinders.
49 CFR 171.8 specifically defines an IBC as not a portable tank.

Like this article?

No marketing emails!

In sum:

The display of placards and package marks (the 4-digit identification number) on the tote (aka: IBC) does not fulfill the requirement to display placards on all four sides of the vehicle.

Conclusion:

I receive questions like this all the time. Sometimes – like this one – I’m surprised by the answer. Make sure you know the regulations before you ship and risk a fine. Contact me with your questions.

Q&A: Is the HazMat endorsement required on the CDL when transporting Class 9?

A substantial percentage of the questions I receive pertain to Class 9 Miscellaneous and its placarding requirements. Here’s one of them:

If a container has a class 9 placards and an orange placard with 4 digit # does the driver have to have hazmat endorsement on their license to haul? Product is agricultural pesticides and fertilizers.

Thanks

I was busy just then and wanted to give him a quick answer but also wished to provide more information. So, here’s my answer:

Short answer: No.

I will provide the long answer later today.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550