A question from someone in the regulated community (03.07.17):
Dear Mr. Stoehr,
I am a dispatcher for an LTL freight company, and I get frequent questions from drivers about using dangerous placards. I found your article online titled “When not to use the Dangerous Placard for Shipments of HazMat”, and I found it very informative, and answered most of the questions I receive; however, there are a couple of situations I was hoping you could clarify.
The first situation is regarding usage on loads containing bulk containers. In the example you provide, it states that dangerous placards cannot be used if there are “several portable tanks of two or more hazardous materials loaded into a tractor trailer.” A situation that we often encounter is one or more portable tank(s) in a load along with one or more non-bulk hazardous materials. If the bulk container(s) are placarded with the appropriate UN specific placards, can a dangerous placard be used to cover the remaining non-bulk shipments, or is it that once a bulk package is introduced into a load, that all items must be placarded individually regardless of the packaging or quantity?
The other situation is similar in nature, but regarding the stipulation for when more than 2205 lbs or more of one category of material is loaded at one loading facility. If we load a trailer with 3000 lbs of corrosive class 8, as well as 1500 lbs of flammable class 3, and 600 lbs of oxidizer class 5.1 (all of which are in non-bulk packaging), can a dangerous placard be used to cover the flammable and oxidizer, or do all three need to be placarded separately?
I greatly appreciate any clarification you may provide; however, I completely understand if you are unable to respond. Thank you very much for you time and consideration.
Of course I was able to respond. I just needed a little time (03.07.17):
I can answer your questions.
Please give me a couple of days to research and reply.
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My response. I didn’t take long (03.08.17):
Thank you for contacting me. I will do my best to answer your questions below.
- The regulations require a vehicle that contains a bulk packaging to display the appropriate placard with the identification number for the HazMat. The identification number must be displayed on the placard or near it on an orange panel or white square-on-point. The regulations allow for the display of the Dangerous placard on a vehicle instead of the separate placards if it contains two or more HazMat in non-bulk packagings that require the display of placards. In answer to your first question: the Dangerous placard may be displayed along with the placard and identification number of a HazMat in a bulk packaging if the vehicle also contains two or more HazMat in non-bulk packagings that require placards in addition to the HazMat in the bulk packaging.
- The Dangerous placard may be displayed instead of the separate placards for two or more HazMat in non-bulk packagings that require the display of placards unless 1,000 kg or more of one HazMat is loaded at one facility. In that case, the placard for the HazMat at or exceeding 1,000 kg must be displayed instead of the Dangerous placard. In answer to your second question: If 1,000 kg or more of one HazMat is loaded at one facility, that HazMat must display its placard. However, if two or more other HazMat of less than 1,000 kg each in non-bulk packagings are loaded at the same facility, the Dangerous placard may be used for them instead of their separate placards.
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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 |