An email question on April 8, 2018:
Sir,
We have tank trailers with a 1000 gallon volume of diesel fuel. If the tank has 100 gallons or less, do they need to be placarded during transport?
Thank you,
My reply the next day (04.09.19):
Thank you for contacting me. I will try to answer your question below.
- Yes. Unless the flash point of the diesel fuel is greater than 93 degrees C (200 degrees Fahrenheit) it will be classified by USDOT as a Class 3 Combustible Liquid.
- A tank trailer (cargo tank) with a capacity of 1,000 gallons is a bulk packaging.
- A bulk packaging of a Class 3 Combustible Liquid is not subject to the full Combustible Liquid Exception and must display placards if it contains any residue of the HazMat.
- Read: General Requirements for Display of Placards.
- As you are no doubt aware if the vehicle must display placards then the driver must have a CDL with the HazMat endorsement.
- Even if the display of placards is not required, anyone involved in the transport of a hazardous material must receive USDOT HazMat Employee Training every three years.
- Drivers of motor vehicles transporting HazMat must receive Driver Training in addition to HazMat Employee Training.
I hope this helps. Please contact me with any other questions.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |
Grateful but with some clarification still necessary:
Thank you very much
We didnt know if it was the size of the container or the quantity @ 118 gallons was the tipping point from ok to move tank vs haz mat and all safety to be followed.
Thanks again
And me with some final guidance:
I understand the confusion. A bulk packaging is defined by the capacity of the packaging, not what it actually holds. The threshold for a bulk packaging is one with a capacity of more than 119 gallons.
Please let me know if I can be of any further assistance.
Perhaps some of your employee require HazMat Employee training?
Contact me anytime with questions.