In an earlier article I wrote about the requirement of the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) to ensure the visibility of placards on a motor vehicle or rail car in transportation. Read: Visibility Requirements for Hazardous Materials Placards.
Those regulations at 49 CFR 172.516(a,b) affect where a carrier must display HazMat placards on a rail car or motor vehicle. Also important – and the subject of this article – are the remaining requirements of that part – §172.516(c-e) – for the display of hazmat placards in all vehicles and all packagings that require placards.
Pursuant to the HMR, each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device must be:
- Securely attached or placed in a holder (Appendix C to to part 172 of the HMR contains recommendations for placard holders). Watch out for adhesive-backed placards or those attached with tape. Will the adhesive hold up for the length of the shipment?
- Located clear of appurtenances and devices: ladders, pipes, doors, and tarpaulins. Note that the locations of these appurtenances and devices, such as a tarp, may change after the placard holders have been affixed, thus putting you into non-compliance.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
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- So far as practicable, located so that dirt and water from the wheels are not directed to it.
- Located away from any marking (such as advertising) that could substantially reduce its effectiveness in communicating the potential hazards of the hazardous material. Placards must be at least three inches (76.0 mm) away from any such marking.
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- Attached in a way that the words or identification number, if required, are displayed horizontally, reading from left to right.
- Maintained by the carrier so that the effects of weather, damage, etc. do not substantially reduce the effectiveness of the placards color, format, legibility, and visibility.
- Affixed to a background of contrasting color, or must have a dotted or solid line outer border which contrasts with the background color.
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- The recommended specifications for a placard holder are found in Appendix C to 49 CFR 172, Subpart F. However, if you choose not to follow these recommendations, the means used to attach a placard may not obscure any part of its surface other than the borders.
- The hinged form of the placards is acceptable provided all of the above requirements are met.
If you are a carrier of hazmat you must provide HazMat Employee training for everyone involved in the transportation of a hazardous material. Drivers of a motor vehicle must receive an additional component of Driver Training.
Please contact me if you have any questions about the transportation of a hazardous material.
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