This email came from India on February 12, 2019:

(India!)

Dear Sir,

Good Morning!

We are the manufacturer of Aluminium powder (UN1309, Aluminum powder, coated, 4.1, PG II). We request your help to know the details from the Hazardous material transportation regulation of IMDG, 2018 Edition 39 -18 Amendment or 49 CFR 172.546 (Class 4 placards specification). Please send the placard specification for class 4 details from the above latest regulations. Now we are following old regulatory placard specifications for the shipments. It is most Urgent. We are expecting your positive reply.

Thanking You.

Well, I’m just a guy from the Midwest so getting an email from India requesting my help is pretty cool. I had to reply right away.

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

• Your question refers to both the International Maritime Organization and their Dangerous Goods Code (IMDG, 2018 Edition 39 -18 Amendment) and the Hazardous Materials Regulations (October 2018 Edition) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).
• The required specifications for the Division 4.1 placard are almost – but not quite – the same for both the IMO and the USDOT/PHMSA.
• Hazardous Materials Regulations of USDOT/PHMSA:
  • 49 CFR 172.519 for general specifications and §172.546 for the Flammable Solid (Division 4.1) placard.
  • Outer dimensions of 250 mm x 250 mm.
  • Line inside the edge 12.5 mm from outside edge.
  • Class or division symbol must be as shown at §172.546.
  • Hazard class number in bottom point of placard must be at least 41 mm high.
  • Any words that appear on placard must be at least 41 mm high.
• IMDG Code:
  • 5.3.1.2.1 for placard specifications and 5..2.2.2 for specimen labels.
  • Outer dimensions of 250 mm x 250 mm.
  • Line inside the edge 12.5 mm from outside edge.
  • Class or division symbol shall be positioned and sized in proportion to those shown in 5.2.2.2.2.
  • Hazard class or division number in bottom point of placard must be at least 25 mm high.

There is much more information in the regulations than I am able to summarize here.

I suggest you contact ICC The Compliance Center to purchase the required placards. Indicate what you need them for and they will be able to sell you what you need.

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

That seemed to do it!

A question via email on January 19, 2018 that was a follow-up to a telephone conversation:

Hi Dan,

I am following up on our phone conversation this morning on shipping combustible liquid.

Also, wondering if pharmaceutical drug products are exempt at all from regulation.

I have suggested to my client that we review the anticipated specific shipping protocols to develop specific shipping instructions – I will likely need your help with that.

Thanks so much!

I will try to provide some guidance and helpful information. See below.

To answer the question about the applicable regulations when shipping a combustible liquid by air:

• Your hazmat is a combustible liquid due to its high flashpoint.
• Per 49 CFR 173.150(f)(2), the USDOT/PHMSA HazMat Regulations do not apply to a combustible liquid in a non-bulk packaging unless a Haz Substance, Haz Waste, or marine pollutant. Note: the limitation to only ground transport is a condition of the option to re-class a flammable liquid to a combustible liquid. It is not a condition in the exception of a combustible liquid from regulation.
• Therefore, as long as it is not a Haz Substance, Haz Waste, marine pollutant or transported in a bulk packaging it is not subject to regulation within the U.S. even if transported by air.
• If transported by air, it cannot be packaged in a bulk packaging since the only type of bulk packaging recognized by IATA is the IBC and its use is limited solely to UN3077 and can’t be used for a combustible liquid.
• A combustible liquid in a single packaging up to 119 gallons is not subject to regulation within the U.S. by any mode of transport. And, a combustible liquid is not regulated by IATA.
• I am not aware of an exception from regulation for pharmaceutical products.
• There is an exception from regulation for a limited quantity of retail products containing ethyl alcohol at 49 CFR 173.150(g).

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

Conclusion:

You may be wondering about his last comment, “I will likely need your help with that.” and to what he was referring.  In addition to providing training for the transport of hazardous materials and the management of waste, I also provide consulting services.  So if you have the training you need but still have a problem, contact me for help.

A question from an environmental consulting firm I work with on January 18, 2018 regarding one of their clients:

Dan,

We have a client who asked what the duration of time that was required to maintain what he called, “UN POP Testing Reports.”

I believe he is referring to package certifications which are given after the packaging meets stress test guidelines and allows the person to request the packaging be made by a container manufacturer and include the specification mark.

I may also be incorrect in that presumption. Perhaps POP is referring to Performance-Oriented Packaging and means something else.

Can you shed some light on this please? Include any regulatory reference if possible.

Thanks

My reply that same day:

A question from someone who had recently attended my Onsite Training (01.18.18):

I just had your DOT training this month, and I ask which placards to use when shipping our product(with a UN 3190 self heating solid). I am still having problems with drivers as to which placards to use.

Yesterday I shipped 123 drums of product each drum contains 200 lbs. This was shipped on 31 skids as a truck load at 24,600 lbs.

This is the problem:

It is my understanding that when I ship this product as a truck load I would use the placard (Spontaneously Combustible 4 )When the driver call the load in to his safety department they requested we use the placard (Spontaneously Combustible 4 with the UN 3190) on it. They would not take the load with out it. Because the amount was over 8,820 lbs it had to have the UN# on it.

So I gave the driver both types of placards. Is this right to do or not? Which placard is right to use in this case.

Thanks for any help you can give.

My reply the same day:

Question (01.15.18):

I called about 2 pages in my catalog (attached page 30 and 45) covering ISO tanks and IBC containers.  The customer has always specified their font height. For example on a 24”x4” tank sign they usually specify a font that is 3” tall with all capital letters – on page 30.  Page 45 has NOS labels and we use a 1” font….unless the text is only 1 line tall and we use a 1.75” tall font.

Is there a rule of thumb or regulations that dictate the font height for a large proper shipping name label or NOS label or ISO label?

I really appreciate the help.

(Two images displaying their product labels were attached to the email)

My answer (01.18.18):

Please see below for a summary of the regulations for the size of package marks.

A question from a concerned truck driver (01.10.18):

I drive lube truck and carry 600 gal go new oil and 400 gal used oil in <<state>> and surrounding states my company told me to remove placards saying not needed. I am questioning them and can’t find answer if I am legal.

My answer (01.10.18):

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

A question (01.04.18):

I’m looking for ability to confirm the DOT rating for particular product we have currently started to make. Is this something you’re able to help provide assistance/training?

I’m here to help, so my reply (01.05.18):

Yes. I can assist you with that.

If you are able to provide a safety data sheet (SDS) or some other technical information I will be happy to provide you with a “snap” classification at no charge.

If you decide to proceed a more formal classification can be provided under my consulting services for a fee.

He was OK with free advice:

I’ve attached two SDS for 70% IPA canister products. The only different to the two products would be the number of wipes in each canister. I believe the classification should be UN3175 – class 4a which one states but the other states UN1987 class 3. The IPA is fully absorbed into the fabric in each product which is why I’d think the classification should be a haz solid. Thank you in advance for any assistance.

Thanks
(SDS’s for two different wipes, both saturated with Isopropanol were attached)

My final answer (01.05.18):

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

• I assume this classification is for the transportation by ground or rail within the U.S. International transport and transport by other modes will require a separate classification. However, I am confident the classification will remain the same.
• Isopropyl alcohol is a Class 3 flammable liquid.
• The wipes are best classified as: UN3175, Solids containing flammable liquids, n.o.s. (Isopropyl alcohlo) 4.1, PG II
• However special provision 47 in column 7 of the Hazardous Materials Table for this entry reads in part (last sentence):

Small inner packagings consisting of sealed packets and articles containing less than 10 mL of a Class 3 liquid in Packing Group II or III absorbed onto a solid material are not subject to this subchapter provided there is no free liquid in the packet or article.

Therefore, as long as both products meet the requirements of special provision 47 (small sealed packets with no free liquids), they are not subject to the USDOT Hazardous Materials Regulations and are not a hazardous material when offered for transportation.

I hope this helps.

Conclusion:

I never heard back so I can only assume all went well.  Here we have a perfect example of someone offering for transport a product as a hazardous material (subject to increased shipping and handling costs) when a perfectly good exception from regulation exists.  If applicable (and in this case I believe it is) the exception has the potential to save this business a lot of money.  Of course, USDOT/PHMSA HazMat Employee training is still required but that is a small price to pay for compliance and the knowledge that comes with it.

An  interesting  question from California (that matters) on January 3, 2018:

Daniel;

I was searching Google when a link to your site came up. We are having to transport sludge and scum from an old wastewater plant across town to a newer plant. We are doing this in a tank truck. What placards do we need to put on the truck?

My reply that same day:

I will do my best to answer your question below.

A question March 7, 2018:

Good day sir!

I am hauling 43,000 lbs of lithium ions UN3480 from NC to CA as truck driver. Are placards and proper shipping papers with emergency numbers required?

Thank you in advance.

I was on it but needed more information:

I can answer your question but I will need more information.

A question on December 16, 2017:

I work for a construction company operating a fuel/lube truck with an 850 gallon tank of off road diesel fuel that I load out of our yard from a 2000 tank we have filled by a fuel supplier. I then drive to our multiple job site locations and fuel all our company owned equipment. I am unclear on weather we need shipping papers for this load. The truck is placarded and I also possess my haz mat and tanker endorsements on my CDL. Do we also need to be registered with the USDOT for haz mat transportation?

My reply two days later:

I will attempt to answer your questions below.

• The transportation of diesel fuel (class 3 combustible liquid) in a bulk packaging (>119 gallons) is subject to DOT regulations.
• It’s transportation requires a shipping paper.
• For simplicity, you may use a permanent shipping paper.
• Since the vehicle is required to display a placard, registration with DOT is required.  Read:  Register with PHMSA/USDOT

I hope this helps.  Please contact me if you have any other questions.