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:
  • A bulk packaging with a capacity of 3,785 L (1,000 gal) or more must display the identification number on all four sides.
  • A bulk packaging with a capacity of less than 3,785 L (1,000 gal) may display the identificatin number on only two opposing sides.
  • There are several options for the display of hazard communication on an intermediate bulk container (IBC).

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!

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.