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.
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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.