PHMSA HazMat Transportation Regulations

Q&A: What hazard communication (marks, labels, & placards) are required on a bulk packaging and a vehicle transporting a bulk packaging?

Q&A: What hazard communication (marks, labels, & placards) are required on a bulk packaging and a vehicle transporting a bulk packaging?

Question1:

If I have a single 55 gallon drum that weighs over 882 is it considered a bulk… Hold it right there!

Answer1:

In an earlier article I addressed the false premise contained in that first question and explained that the packaging described (55-gallon drum) is not a bulk packaging and is violation of the HMR if it has a maximum net mass of more than 882 lbs; I suggest you read that article first (Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?). In this article I’ll answer the remaining questions poased as if it is a bulk packaging (it isn’t).

Question2:

“…and would it require a un number…”?

Answer2:

“…and would it require a un number”?

  • Yes. The HazMat’s identification number must be marked on both a bulk and non-bulk packaging.
  • There are several options for the display of the identification number on a bulk packaging:

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Question3:

“next question if I have a bulk container that requires a un number but I also have non bulk waste under the same un number do I have to placard my trailer with both the un number and a class placard or will the un number cover both.”?

Answer3:
  • Both the placard and identification number must be displayed on the vehicle.
  • If the identification number displayed on a bulk packaging is not visible in transportation, e.g., it is inside a cargo trailer, then it is necessary to display the identification number on all four sides of the vehicle.
  • A bulk packaging containing any amount of any HazMat requires the vehicle to display the applicable placard for the HazMat on all four sides of the vehicle.
  • In this case the vehicle must display the identification number and the applicable placard for the HazMat in the bulk packaging. This can be displayed in one of three ways:
    • The identification number may be displayed on the placard.
    • The identification number may be displayed near the placard on an orange panel.
    • The identification number may be displayed near the placard on a white square-on-point.
  • If an identification number is displayed on a vehicle it must represent all of the HazMat of that Class in the vehicle. Since you indicate you have a bulk and non-bulk packaging of the same identification number, a placard representing the Class and the identification number must be displayed on all four sides of the vehicle. Read: When not to Display and ID# on a Vehicle

I hope this helps. Please contact me with any other questions.

Conclusion:

A tough question because the inquisitor started with an incorrect understanding that its OK for a 55-gallon drum to weigh more than 882 lb – it’s not!

Daniels Training Services provides HazMat Employee Training

Sometimes knowing the right question to ask requires a basic understanding of the USDOT/PHMSA Hazardous Materials Regulations. My monthly HazMat Employee Training Webinars can do just that.

Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?

Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?

Question:

If I have a single 55 gallon drum that weighs over 882 lb is it considered a bulk Wait! Stop! That question contains a false premise. I can’t consider the next question until I explain a bulk packaging and the limits on the maximum net mass of a 55-gallon  drum. The next question will have to wait for another article.

Answer:

Thank you for contacting me. Please allow me to provide some clarification on the term “bulk packaging”.

  • A bulk packaging is defined at 49 CFR 171.8 in the Hazardous Materials Regulations (HMR).
  • It reads in part:

…a bulk packaging has: * * *

(1) A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;

(2) A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or

(3) A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.

emphasis added.

Read: Bulk Packaging for HazMat Explained!

  • You do not state whether the HazMat in the drum is a liquid or solid – I presume it is not a gas – but, regardless, the maximum capacity of a bulk packaging must be greater than 450 L (119 gallons) for both a liquid and a solid HazMat.
  • It is interesting to note that a bulk packaging for a solid must have a maximum net mass of greater than 400 kg (882 lb) AND a maximum capacity greater than 450 L (119 gallons).
  • You indicate it is a 55-gallon drum. Therefore, its maximum capacity is 208 L. This can’t be a bulk packaging.
  • You also write it weighs more than 882 lb (400 kg). Since this is the gross mass (weight of packaging and HazMat), I will presume the net mass (weight of the HazMat only) is also greater than 400 kg (882 lb); regardless, this is not enough to meet the criteria of a bulk packaging. *It is – in fact – a violation of the packagings specification and will be addressed later*

In sum: What you describe is a non-bulk packaging because its maximum capacity is well below the threshold required for a bulk packaging.55-gallon drum of hazardous waste

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Now, how about that 55-gallon drum weighing more than 882 pounds?
  • A 55-gallon drum used for the transportation of a HazMat must be designed, manufactured, tested, & marked to meet a specification acceptable to USDOT/PHMSA.
  • I presume the specification in use here, as in most transport of HazMat in non-bulk packagings and IBCs, is the United Nations Performance-Oriented Packaging Standards (aka: UN Standard). The requirements for this specification are found at 49 CFR 178, subpart L.
  • These regulations specify limits on the maximum capacity of all drums made to the UN standard; they are:

Drum TypeMaximum CapacityMaximum Net Mass
Steel drums450 L (119 gallons)400 kg (882 pounds)
Aluminum drums450 L (119 gallons)400 kg (882 pounds)
Metal drums other than steel or aluminum450 L (119 gallons)400 kg (882 pounds)
Plywood drums250 L (66 gallons)400 kg (882 pounds)
Fiber drums450 L (119 gallons)400 kg (882 pounds)
Plastic drums450 L (119 gallons)400 kg (882 pounds)

A plywood drum?!?

  • As you can see from the table, no drum of any composition made to the UN Standard may exceed a maximum net mass of 400 kg (882 lb).
  • If you have a 55-gallon drum that exceeds a maximum net mass of 882 pounds, it is a violation of the HMR at 49 CFR 173.22(a)(2) for the shipper to offer it for transportation to the carrier.
  • It is a violation of the HMR at 49 CFR 177.801 for the carrier to accept a consignment containing a 55-gallon drum that exceeds a maximum net mass of 882 pounds.

I hope this helps. Please contact me with any other questions.

Daniels Training Services, Inc.

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Conclusion:

He didn’t contact me with any follow-up questions. However, read here for the article that answers the question he posed after this one.

Q&A: What do I do with a Marine Pollutant in a non-bulk packaging?

Q&A: What do I do with a Marine Pollutant in a non-bulk packaging?

Question1:

Good Afternoon Daniel,

Our company recently noticed some label changes on a product we use and sometimes ship to our customers. Recently, we’ve begun seeing a class 9 UN3077 label as well as a “marine pollutant” pictogram. I’m aware of the marine pollutant exception in 49CFR 171.4 (c) that states non bulk packages are unregulated unless offered for vessel transport (i.e. on land)

The product in question comes in 5 gallon pails, and weigh ~50 lbs. The product is defined as a “solid” by the manufacturer.

My question is, is the “non-bulk” receptacle weight of 882 lbs per “bucket” or gross weight of all buckets combined? Is there a limit of how many “non-bulk” containers we can ship without being regulated?

Hopefully this isn’t too confusing as I’m trying to make sense of this just to ask my questions.

Thanks,

Answer1:

Thank you for contacting me. You have the right idea. Please see below.

  • For transportation on the ground in the U.S. a non-bulk packaging is not subject to regulation as a marine pollutant.
  • The determination of a bulk or non-bulk packaging is based on the capacity of an individual packaging. It is not based on the gross weight of the package or the combined weight of the consignment.

So…

  • A 5-gallon pail weighing 50 lb – and therefore a non-bulk packaging – can not be a marine pollutant when transported on the ground in the U.S. It does not matter if there is one 5-gallon pail or 500 of them on the truck.
  • Read: What is a bulk packaging?
  • Read: What is a marine pollutant?

I hope this helps. Please contact me with any other questions.

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

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Question2:

Thank you Daniel. Now that we have the marine pollutant question out of the way, I have another question. The product is also labeled as a UN3077 Class 9 hazmat. It is of my understanding that class 9 misc. hazmat is exempt from placarding, and all hazmat’s are exempt as long as you transport <1,001 lbs. The only requirements we’d have to comply with are marking the material correct? Would employees need hazmat training and would the shipment have to be shipped with a hazardous materials manifest?

Thank you,

Answer2:

You are partially correct. Please see below.

  • You are correct that it is not required to display the Class 9 Miscellaneous placard on a vehicle when operated in the U.S. regardless of the quantity or packaging of the Class 9 Miscellaneous.
  • You are not entirely correct that all HazMat is exempt from placarding below 1,001 lb.
    • Some HazMat must be placarded regardless of amount or packaging if they are included in Placard Table 1 (e.g., Dangerous When Wet).
    • Some HazMat must be placarded regardless of amount if in a bulk packaging (even one drop).
    • However, for HazMat in Placard Table 2 (most of ’em) and in a non-bulk packaging, the display of placards is not required if the aggregate gross weight is less than 454 kg (1,001 lb).
  • Though not required to display placards, all the remaining HazMat Regulations apply to the transportation of a Class 9 Miscellaneous (and any other HazMat that does not require the display of placards):
    • Package marks & labels.
    • HazMat shipping paper with emergency information.
    • HazMat Employee training for all personnel involved in its transportation. Also, Driver Training for operators of motor vehicles.

I can provide HazMat Employee training including Driver Training.

Please contact me with any other questions.

Conclusion:

Questions about marine pollutants are common. This is, in part, due to the fact that the classification of a Marine Pollutant per the HMR differs from its classification in the dangerous goods regulations of IATA & IMO.

No matter your HazMat / dangerous good or the mode of transport, I can provide the training you need to comply with both domestic and international regulations.

Daniels Training Services, Inc.

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More Information:
  • The Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) creates and enforces the Hazardous Materials Regulations (HMR) for the transportation of hazardous materials (HazMat) to, from, or through the U.S.
  • The Dangerous Goods Regulations of the International Air Transport Association (IATA) are produced in consultation with the International Civil Aviation Organization (ICAO) and are the guide recognized by the world’s commercial airlines for the transportation of dangerous goods by air.
  • The International Maritime Organization (IMO) is the source of the Dangerous Goods Code for the international transportation of dangerous goods by vessel.
Q&A: Does the transport of 55-gallon drums containing the residue Class 3 Flammable Liquid require a HazMat Endorsement on the driver’s CDL?

Q&A: Does the transport of 55-gallon drums containing the residue Class 3 Flammable Liquid require a HazMat Endorsement on the driver’s CDL?

Question:

Subject: Empty class 3 flammable drums

Message Body:
Carry 8 to 12 class 3 flammable drums back to yard to get refill small amount of product still in drums drums mark small flammable sticker do I need hazmat on my license.

Answer:

Thank you for contacting me. I will try to answer your question below. More information would be helpful, but I think I can confidently answer: No. You do not require the HazMat endorsement on your CDL for the transport of packagings containing the residue of a HazMat; in this case a Class 3 Flammable Liquid.

The reason:

  • The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. DOT (USDOT/PHMSA) include the Empty Packaging Exception at 49 CFR 173.29. Under this exception a packaging with the only the residue of a HazMat does not require the display of placards on the vehicle. It is also excepted from other hazard communication normally required by the HMR.

Read: Shipment of Empty HazMat Packagings and the Need for HazMat Labels, Placards, Markings, & etc.

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

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That’s the easy part. The rest is a little more complicated.

  • Pursuant to the commercial motor vehicle (CMV) regulations of the Federal Motor Carrier Safety Administration within the U.S. DOT (USDOT/FMCSA) at 49 CFR 383.93(b)(4), a driver of a CMV requires the HazMat Endorsment on their CDL only when the vehicle requires the display of placards or is transporting any quantity of a select agent or toxin identified at 42 CFR 73.
  • Since placards are not required to be displayed on the motor vehicle for the transport of packagings with only HazMat residue, the HazMat endorsement is not required on the CDL of the driver.

However…

  • The consignment remains a HazMat and is subject to other requirments of the HMR including HazMat Employee Training with Driver Training.
  • The driver and the motor vehicle may be subject to other requirements of the CMV regulations depending on the vehicle’s gross vehicle weight rate, the number of passengers carried, and whether transportation in interstate or intrastate.

Please contact me with any other questions.

Class 3 Flammable Liquid Placards

Class 3 placard with identification number for Printing Ink or Printing Ink Related Material (UN1210) and Resin Solution (UN1866)

Conclusion:

Search through my Q&A’s and you’ll find many questions like this one, “Do I need the HazMat Endorsement on my CDL to haul this?” Be sure to contact me before you transport a load of HazMat and you are unsure of your responsibilities under the regulations of PHMSA or FMCSA.

Q&A: Can we print our own HazMat labels? Specifically, the Class 9 Lithium Battery label?

Question:

Good morning I was on your web site looking for some information as it pertains to application of the class 9 lithium battery.

My questions is do we have to buy labels and hand apply it or can we direct flexo print the diamond to spec. we print a lot of UN Corrosive diamonds on corrugated and I would like to do so with this class 9.

We have a very bright white that we print and are able to over print the BK with no wet out keeping it very legible. Is this option ?

Thank you

Daniels Training Services, Inc.

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Answer:

Thank you for contacting me. In short, it is not necessary to purchase labels and hand apply them to a package that requires the display of labels. The use of the word “labels” by the Hazardous Materials Regualtions of USDOT/PHMSA is unfortunate since it leads one to believe a separate adhesive-backed label (aka: a sticker) must be affixed to the package. The language at the beginning of 49 CFR 172.407 Label specifications reads, “…Each label, whether printed on or affixed to a package…” So, the label may be pre-printed on the packaging or it may be affixed.

§172.407 goes on to describe the specifications for a label’s durability, design, size, and color. As long as the label meets the design specificaitons of §172.407 it can be purchased or made by the shipper.

Read: HazMat Label Specifications

Additional specifications for and an image of the Class 9 Lithium Battery label are at §172.447.

Class 9 Lithium Battery Label

Please contact me with any other questions.

Conclusion:

And that did it!

This answer applies to all hazard communication of the HMR, whether it be labels, marks, or even placards! Who made it and how doesn’t matter as long as it meets the specification for its design and the regulations for its display.

 

Q&A: Is it necessary to display placards if I’m hauling 2,205 lb of just one type of HazMat (Division 2.2)?

Question1:

Hello,

I was hoping to get some clarification on this. I have highlighted the section in red that I am questioning. If I have less than 2,205lbs of just one type of hazard identified in table 2, non-flammable gas 2.2 to be exact, then it doesn’t need to be placarded? Or does it if it is over 1,001 lbs? It seems like the 1,001 lbs rule applies if you are combining 2 or more hazards identified in table 2?

https://www.govregs.com/regulations/49/172.504

(b) DANGEROUS placard. A freight container, unit load device, transport vehicle, or rail car which contains non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of this section may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in table 2 of paragraph (e) of this section. However, when 1,000 kg (2,205 pounds) aggregate gross weight or more of one category of material is loaded therein at one loading facility on a freight container, unit load device, transport vehicle, or rail car, the placard specified in table 2 of paragraph (e) of this section for that category must be applied.

(c) Exception for less than 454 kg (1,001 pounds). Except for bulk packagings and hazardous materials subject to § 172.505, when hazardous materials covered by table 2 of this section are transported by highway or rail, placards are not required on

(1) A transport vehicle or freight container which contains less than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by table 2 of paragraph (e) of this section; or

(2) A rail car loaded with transport vehicles or freight containers, none of which is required to be placarded.

Answer1:

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

  • The text highlighted in red applies to two separate placarding scenarios.
  • 49 CFR 172.504(b) applies to the use of the DANGEROUS placard.
  • §172.504(c) is an exception from the general placarding requirements of §172.504(a).
  • If a vehicle contains less than 454 kg (1,001 lb) of a table 2 HazMat (e.g., Division 2.2), in a non-bulk packaging, placards are not required to be displayed on the vehicle.
  • The DANGEROUS placard may be used when two or more HazMat of Table 2 in non-bulk packaging that require the display of placards are transported at the same time. The text you highlight in red states that if 1000 kg (2,205 lb) of HazMat is loaded at one facility, it must be placarded separately (per its own placarding requirements) and is not covered by the DANGEROUS placard.

I hope this helps. Please contact me with any other questions.

Question2:

Daniel,

Thank you for your response. So you are saying as long as we have under 1001 lb. of 2.2 cylinders we do not have to placard? Each cylinder weighs 60lbs. If we go over that weight threshold then we would have to placard? Can you have 1001lb in a pickup and 1001lb in a trailer behind it? Or 1001lb per combination?

Thanks!

Answer2:

Please see below.

  • Correct. The placarding threshold for a Division 2.2 in a non-bulk packaging is 454 kg (1,001 lb) or more.
  • A pickup towing a trailer are subject to the USDOT/PHMSA Hazardous Materials Regulations as two separate transport vehicles. Each with its own placarding requirement. Therefore, if you had 1,000 lb of Division 2.2 in the pickup and 1,000 lb of Division 2.2 in the trailer (both in non-bulk packagings) then no placards are required on either.
  • A person operating a vehicle that does not require the display of placards does not require the HazMat endorsement on their CDL. They would require HazMat Employee Training with the additional component of Driver Training.

Contact me the next time your USDOT/PHMSA training is due to expire.

Please contact me with any other questions.

Conclusion:

 

Q&A: Is a 55-gallon drum of waste gasoline also a reportable quantity (RQ) of a hazardous substance?

Question:

I’d like to commend you for the great Q&A on your website. I have referred others to answers on HW and HM Qs over the years, as you always do a great job of explaining why something does/doesn’t apply. I saw your answer that there is no RQ for gasoline as an HM: Q&A: How much diesel fuel is a reportable quantity (RQ) of a hazardous substance?, but what about when it’s waste gasoline? As it carries a D001 waste code it seems like it would apply in cases where it exceeds the D001 threshold (100 lbs).

Answer:

Thank you for contacting me. You are correct, as a hazardous waste with the D001 waste code, gasoline could be a RQ of a hazardous substance. In that case though the RQ applies to the D001 and not to the gasoline.

Please see below for clarification:

  • As documented in the above-referenced article, the definition of hazardous substance at 49 CFR 171.8 of the USDOT/PHMSA Hazardous Materials Regulations specifically excludes petroleum and related substances:Hazardous waste container

The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance in appendix A to § 172.101 of this subchapter, and the term does not include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas).

  • Gasoline and diesel as a petroleum product are excluded from consideration as a hazardous substance and therefore can’t have a reportable quantity (RQ).
  • However, the list of hazardous substances at Appendix A to § 172.101—List of Hazardous Substances and Reportable Quantities includes the USEPA hazardous waste code for Ignitability (D001) with a RQ of 100 lb.
  • It is quite likely that gasoline as a waste for disposal will have the Characteristic of Ignitability and the D001 waste code. It is less likely – though possible – that diesel fuel as a waste will have the Characteristic of Ignitability and the D001 waste code.
  • As noted above, the reportable quantity (RQ) of D001 in a single container is 100 lb. Therefore, if a single container we
FAQ: Can a damaged, defective, or recalled (DDR) lithium cell or battery be managed as universal waste?

FAQ: Can a damaged, defective, or recalled (DDR) lithium cell or battery be managed as universal waste?

A: Maybe.

When discarded, most lithium-ion (secondary batteries) and lithium primary batteries in use today are likely to be hazardous waste due to ignitability and reactivity (D001 and D003, respectively). With the exception of households, the generator of a waste is responsible for determining whether the spent lithium batteries they generate are hazardous waste and, if they are,
how they are to be managed in compliance with Federal and State hazardous waste requirements.

One compliance option is to manage the hazardous waste lithium batteries as a universal waste.

A handler of universal waste may only manage broken or damaged lithium batteries as universal wastes if the breakage or damage does not constitute a breach in an individual cell casing. The definition of battery in 40 CFR 273.9 does not explicitly state that all batteries must be whole; however, the definition includes an intact, unbroken battery from which the electrolyte has been
removed (60 FR 25492, 25504; May 11, 1995).

Additionally, the requirements for handlers of universal waste allow certain management activities, such as sorting and mixing batteries, provided the batteries or cell casings are not breached and remain intact (sections 273.13(a)(2) and 273.33(a)(2)). The disassembly of a battery pack into individual modules or cells with no damage done to the cell casing does not make a battery damaged or defective.

In sum: A DDR lithium cell or battery may be managed as a universal waste as long as the damage does not constitute a breach in the cell casing.

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Damaged, defective, or recalled (DDR) batteries may not be transported by air. In addition, they must comply with specific Department of Transportation (DOT) packaging requirements found at 49 CFR 173.185(f).

Q&A: Are orientation arrows required on a package containing pressurized gas?

Q&A: Are orientation arrows required on a package containing pressurized gas?

Question:

Hello,

Good afternoon! My name is Jane Doe, I’m from Company’s Regulatory Affairs department and I have been researching hazmat shipping regulations. I understand that orientation arrows are required on two opposite, vertical sides of the package if the package contains liquid hazardous materials. However, I’m wondering if any such requirements apply to pressurized gas hazardous materials? Are orientation arrows required in that case as well, or does the regulation just apply to liquids?

Thank you so much for your help!

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
Answer:

Thank you for contacting me. Please see below.

I hope this helps. Please contact me with any other questions.

Q&A: Commercial Driver’s Licensed and HazMat Endorsement in California

Q&A: Commercial Driver’s Licensed and HazMat Endorsement in California

Question:

Hey Daniel, reading over your answered questions on your website and how full and complete you answer questions.My Question:

In California CVC 32000.5 states in part

” and a motor carrier who transports for a fee in excess of 500 pounds of hazardous materials of the type requiring placards pursuant to Section 27903 , shall be licensed in accordance with this code, unless specifically exempted by this code or regulations adopted pursuant to this code.  This license shall be available for examination and shall be displayed in accordance with the regulations adopted by the commissioner.”

If I am charging a fee for a hazmat delivery and it’s over 500 lbs in California does the driver of the hazmat needs a CDL hazmat endorsement. Throwing out the 1,001 exemption as California is requiring stricter limits of 500.

If you could also take account “chp 800c” memo stating 500 lbs for a fee that needs to be placard if hauled in greater amounts

Thanks for your time.

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

International and Domestic
Answer:

Please see below for answers to your questions:

  • No. The driver of a motor vehicle in the situation you descrube does not require the HazMat Endorsement on their commercial driver’s license (CDL).
  • Federal regulations of the Federal Motor Carrier Safety Administration within the U.S. Department of Transportation (USDOT/FMCSA) at 49 CFR 383.93 require a driver to have the HazMat endorsement on their CDL if they operate a motor vehicle transporting certain quantities and types of hazardous materials (HazMat). This requirement applies to interstate or intrastate carriers.
  • The HazMat endorsement on the CDL is required to be obtained in either of the following circumstances:
    • The vehicle transports a quantity of HazMat that requires the display of placards per the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. DOT (USDOT/PHMSA) at 49 CFR 172.504.
    • The vehicle transports any quantity of a select agent or toxin listed at 42 CFR 73.
  • The California Highway Patrol (CHP) requires a person who operates a motor vehicle transporting hazardous materials in certain quantities to obtain a Hazardous Materials Transportation License (HMTL) from CHP. This requirement applies to interstate or intrastate carriers.
  • A HMTL is required to be obtained from CHP in either of the following circumstances:
    • The shipment of HazMat requires the display of hazard warning placards per the HMR of USDOT/PHMSA.
    • The shipment of HazMat exceeds 500 pounds, is being transported for a fee (for-hire), and the material would normally require placards if shipped in a greater quantity. In other words, the HazMat doesn’t require the display of placards at its current type and quantity, but it would if in a greater quantity.
For more information or to obtain a HMTL, refer to the following CHP forms availalbe at www.chp.ca.gov:

  • CHP 361E, Hazardous Materials Transportation License – Application Instructions
  • CHP 361M, Application for Hazardous Materials Transportation License
  • It is importatnt to note that the Federal regulations of USDOT/PHMSA are referenced by CHP, but can’t be changed in any way by it. In short: California can’t require more stringent requirements than USDOT/PHMSA for placarding or other regulations for HazMat transportation.
  • CHP can, however, be more strict in its state regulations for the licensing of commercial motor vehicles (these are the regulations of USDOT/FMCSA). Therefore, CHP can require a HMTL in circumstances where neither the CDL nor the HazMat Endorsement are required.
  • I referred to the following document for this answer: State of California / Department of California Highway Patrol / Vehicles Transporting Hazardous Materials / CHP 800c (Rev. 9-15) OPI 062.
  • Note: This quantity of HazMat (500 lb) may require the display of placards per USDOT/PHMSA if in a bulk packaging (e.g., IBC) or a Table 1 HazMat (49 CFR 172.504(e)).

I hope this helps. Please contact me with any other questions.

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