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General Placarding Requirements

General Placarding Requirements

49 CFR 172.504 – General Placarding Requirements contains the applicability, scope, and general requirements for the use of placards when transporting a hazardous material.  §172.504(a) identifies the five (5) types of packagings and modes of transportation that will require placards, unless excepted.  A closer look at these five defined terms is important since packagings and methods of transportation not included in §172.504(a) will not require a placard.

49 CFR 172.504(a) reads:

(a) General. Except as otherwise provided in this subchapter, each bulk packaging, freight container, unit load device, transport vehicle or rail car containing any quantity of a hazardous material must be placarded on each side and each end with the type of placards specified in tables 1 and 2 of this section and in accordance with other placarding requirements of this subpart, including the specifications for the placards named in the tables and described in detail in §§ 172.519 through 172.560.

The five packagings and methods of transportation identified in §172.504(a) as subject to placarding requirements are:

  • Bulk packaging
  • Freight container
  • Unit load device
  • Transport vehicle
  • Rail car

Each of the above is defined in detail at 49 CFR 171.8 and summarized below:

Bulk Packaging:

A bulk packaging is first of all a packaging, which is defined at §171.8 as a receptacle and any other components or materials necessary for the receptacle to perform its containment function.  In other words, it is the receptacle or container that the HazMat is contained in when in transportation.  A bulk packaging however is distinct from a non-bulk packaging in that it has a maximum capacity above specified thresholds:

  • >119 gallons for a liquid
  • >882 pounds and >119 gallons for a solid
  • >1000 pounds water capacity for a gas

The definition of a bulk packaging specifically excludes a barge or vessel even if it meets the maximum capacity criteria.

Freight Container:

A freight container means a reusable container having a volume of 64 cubic feet or more (thus a bulk packaging), designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.

Unit Load Device:

Unit load device means any type of freight container (see above), aircraft container, aircraft pallet with a net, or aircraft pallet with a net over an igloo.  The use of this term appears to be limited to transportation by air.

Transport Vehicle:

Transport vehicle means a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or rail car used for the transportation of cargo by any mode.  This is the first inclusion of a method of transportation in §172.504(a) is limited to transportation by highway or rail only.

Rail Car:

A term already included in the definition of Transport Vehicle (see above), rail car means a car designed to carry freight or non-passenger personnel by rail, and includes a box car, flat car, gondola car, hopper car, tank car, and occupied caboose.  This term only applies to transportation by rail.

So what terms aren’t included in the above and what does it matter?

The following terms are not included in §172.504(a) and therefore do not require the use of placards no matter the amount or type of hazardous material in transportation:

  • Non-bulk packaging (eg. 55-gallon drum)
  • Aircraft
  • Barge or vessel

You’ve likely seen placards affixed to trucks on the highway and rail cars when stopped at a rail crossing.  But you’ve never seen them on a 55-gallon drum, or a boat or a plane.  And now you know the reason why.  Attend my HazMat Employee Training and learn even more.