Just a quick question June 19, 2018:
Is carrying 40 – 55 gallon drum of NaOH on a box trailer considered bulk?
Sent from my iPhone
My reply just an hour later:
No it is not.
Please see below for an explanation:
- A bulk packaging is one with a capacity of greater than 119 gallons. Read: Bulk Packaging for HazMat Explained!
- Your containers are 55 gallons each.
- The total volume of the shipment is not a factor.
- You may, however, need to display the identification number for the hazardous material on the vehicle.
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Her gracious reply:
Thank you. That’s what I thought but just wanted to make sure.
I wasn’t done (I have so much to share!):
You’re welcome!
You may wish to read this article I wrote indicating when it is necessary to display the identification number on a transport vehicle if it contains a large quantity of a single HazMat: Vehicle Marking Requirements for Single HazMat.
That spurred another question (06.20.18):
I read the other article you sent and it did clear up when to use numbered placards on a straight forward shipment. Other scenarios would also be helpful.
- What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?
- Same scenario but you picked them up from two separate shippers?
- Another: Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?
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My reply the next day:
I will attempt to answer your questions below.
- Scenario 1: “What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?”
- Answer: In this scenario you must display the applicable placards for each HazMat unless one of the placarding exceptions at 49 CFR 172.504(f) apply. If both HazMat are in a non-bulk packaging you must not display the identification number. If either of the HazMat are in a bulk packaging you must display its identification number on or near the placard.
- Scenario 2: “Same scenario but you picked them up from two separate shippers?”
- In this scenario the vehicle would display the applicable placard and identification number for the first shipment (assuming all of the other conditions of 49 CFR 172.301(a)(3) are met). When the second shipment is picked up the placard for the second HazMat must be displayed, but not its identification number. The identification number and placard from the first shipment would continue to be displayed (this is based on a conversation with the HazMat InfoLine. It is not clear from the regulations. I could not find a letter of interpretation to confirm).
- Scenario 3: “Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?”
- If both HazMat picked up from one shipper then Scenario 1 from above will apply.
- If picked up from two separate shippers then Scenario 2 will apply.
I hope this helps. Please don’t hesitate to contact me with any other questions.
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That seemed to answer all of his/her questions.
I frequently receive questions about placarding vehicles. As you can see from this Q&A, there are many scenarios to consider and each may require a different display of placards. If you are a carrier of HazMat, make certain you display the correct placards. If you are a shipper of HazMat (i.e., you offer the HazMat to a carrier for transport), make certain you offer the correct placards to the driver.
As a shipper or a carrier, make certain all of your employees with a direct affect on the safe transport of HazMat receive initial and triennial HazMat Employee training.