The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) mandate the display of placards on certain vehicles and packagings when they contain a hazardous material (HazMat). Compliance is relatively simple if the HazMat has only one hazard. But what of a HazMat with a subsidiary hazard – or two! The purpose of this article is to identify and explain the USDOT/PHMSA regulations for the display of placards of a subsidiary hazard.
General placarding requirements:
The general placarding requirements of the HMR at 49 CFR 172.504(a) require the display of a placard for any quantity of a HazMat in any of the following:
- Bulk packaging
- Freight container
- Unit load device
- Transport vehicle
- Rail car
Left at that it would be pretty simple: placards must be displayed for all HazMat, both primary and subsidiary hazards. However, it isn’t left at that.
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An exception from placarding:
§172.504(c) allows for an exception from the display of placards on a transport vehicle or freight container under the following conditions:
- Transport is by highway or rail. Other modes (air and vessel) have other placarding requirements.
- HazMat is not in a bulk packaging. All bulk packagings – well, almost all – must display the require placards.
- HazMat is not identified in §172.505 (more on that later in this article).
- HazMat is not identified in Table 1 but is identified in Table 2 at §172.504(e). The HazMat in Table 1 pose a greater risk to heath, safety, and property when transported than do the HazMat in Table 2.
- Transport vehicle or freight container contains less than 454 kg (1,001 lb) aggregate gross weight of HazMat.
Question: What if a vehicle contains less than 454 kg of a HazMat that has a primary hazard in Table 2 but a subsidiary hazard identified at §172.505 and – oh what the heck – has another subsidiary hazard identified in Table 2. e.g., UN1746, Bromine trifluoride, 5.1 (6.1)(8), PG I, Poison Inhalation Hazard Zone B.
Answer: Placards for both the primary hazard (Division 5.1 Oxidizer) and the subsidiary hazard of Division 6.1 Poison Inhalation Hazard Zone B must be displayed. The placard for the remaining subsidiary hazard (Class 8 Corrosive) may be displayed. Even though the aggregate gross mass of the HazMat is less than 454 kg, the fact that Division 6.1 Poison Inhalation Hazard Zone B is identified at §172.505(a) means that the exception from placarding does not apply. Further, §172.505(a) directs that the POISON INHALATION HAZARD or POISON GAS placard, as appropriate, must be displayed in addition to any other placard required for that material in §172.504 (emphasis added). Finally, subject to §172.505(d), the remaining subsidiary placard (Class 8 Corrosive) may be displayed but is not required. Refer to LOI 11-0107 and 07-0230
Placarding for a subsidiary hazard:
So what, if any, are the requirements for placarding a subsidiary hazard that isn’t identified in §172.505? Their is no clear-cut answer. To form any kind of an answer we must go to §172.505 – Placarding for subsidiary hazards. Here the HMR identifies three specific types of HazMat that require the display of placards even if it is a subsidiary hazard. And, as we saw at §172.504(c), if a HazMat is identified in §172.505 (even as a subsidiary hazard) the exception from placarding does not apply to the primary hazard class either.
The three HazMat identified in §172.505 that require the display of placards, no matter what, are as follows:
- Each transport vehicle, freight container, portable tank, unit load device, or rail car that contains a poison inhalation hazard must display either the POISON INHALATION HAZARD or POISON GAS placard as appropriate in addition to any other placard required for that HazMat by §172.504.
- In addition to the RADIOACTIVE placard which may be required at §172.504(e), each transport vehicle, portable tank, or freight container that contains 454 kg (1,001 lb) or more of non-fissile, fissile-excepted, or fissile uranium hexafluoride must also display the placard(s) for CORROSIVE and POISON.
- Each transport vehicle, portable tank, freight container, or unit load device that contains a HazMat with a subsidiary hazard of Division 4.3 Dangerous When Wet must display the DANGEROUS WHEN WET placard in addition to any other placard that may be required by §172.504.
And one final item at §172.505(d): It is acceptable – but not required – to display the appropriate placards for subsidiary hazards even when not required by the HMR. Of course, other than those three above, it is not required to display placards for subsidiary hazards.
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Some final notes to consider when displaying placards for subsidiary hazards:
- Pursuant to §172.519(b)(4), the placard for both the primary and subsidiary hazard must include the hazard class or division number in the lower corner of the placard; there is no difference in appearance between the placards for primary and subsidiary hazards. However, a permanently affixed subsidiary placard that does not include the hazard class or division number may continue to be used under the following conditions:
- It was installed prior to September 30, 2001.
- Transport by highway or rail only.
- The color tolerances of §172.519(d) are maintained.
- When displayed as an option per §172.505(d), the display of both subsidiary and primary placards must be in conformance with the general requirements of §172.504. Meaning, you can’t placard just for the subsidiary hazard and not the primary. Refer to LOI 11-0298
- The DANGEROUS placard can’t be used to represent the subsidiary hazard of a HazMat. Refer to LOI 11-0076
- The HMR do not specify where on a vehicle or packaging a placard for a subsidiary hazard must be placed in relation to the placard for the primary hazard (i.e., above, below, to the left or right). Refer to LOI 07-0071
- The requirements for visibility and display of placards at §172.516 apply to placards for both primary and subsidiary hazards. Refer to LOI 07-0071
Conclusion:
The HMR do not clearly state that you are not required to display the placard of a subsidiary hazard. Instead, at §172.505 it provides three situations when the placard for a subsidiary hazard must be displayed and ends with an option to display the placard for a subsidiary hazard when not required.
If you’ve read to the end of this article you must surely be involved in the transportation of a hazardous material. Perhaps as the person who offers the HazMat for transportation (i.e., the shipper) or as the person transporting it (i.e., the carrier). Whichever applies you must provide initial and triennial HazMat Employee training to all personnel with a direct effect on the safe transportation of hazardous materials; this may include an additional component for Driver Training.
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