Q&A: Display of Identification Number on Bulk Packagings in Transportation

PHMSA HazMat Transportation Regulations

Q&A: Display of Identification Number on Bulk Packagings in Transportation

Daniel Stoehr

November 22, 2016

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Here is a type of question I receive frequently (5.11.16):

Good Morning.
I’m pulling a gooseneck trailer which is carrying two one- way totes of 1760 (corrosive solution) and 1 tote of 1824 (50% caustic). Both totes have proper labels and Id’s on opposite ends. Can I placard the trailer using only (8) corrosive placards or do I need 2 sets of placards with proper id’s?

My reply that day:

That is a good question. I will try to answer it here, if you need more information I can provide that later.

You are required to display the identification number for each bulk packaging of a different HazMat that you have on your vehicle. In this case you have two different identification numbers. You must display both on all four sides of the vehicle.

However, if the identification numbers are visible on the totes while in transportation on all four sides of the vehicle, then it is not necessary to display the identification number with the placards on the vehicle.

I hope this helps. Please don’t hesitate to contact me with any other questions.

He must have been waiting for an answer because within a few moments I received this reply with further questions:

Daniel,

First of all allow me to thank you for your prompt response.

Second, did i read correctly that a newsletter was available for purchase?

Third, I’m very aware of the difficulty of answering a DOT hazmat load question where there is no gray area.

So with that in mind, I have loaded 1 bulk package with ID’s on all four side thus not having to placard the vehicle.

But with 3 totes, 2 with 1760 and 1 with 1824, and only 2 id’s on opposite ends of each tote would that still allow me to use only 8 Corrosive placards?

I know…wow.

My reply that same day:

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You can display the solely the Class 8 placard on all four sides of the vehicle as long as both of the two distinct identification numbers (1760 & 1824) are visible on all four sides.

If the identification numbers are not visible on all four sides of the vehicle, then it is necessary to display them on the vehicle. This can be done in one of three ways:

On the placard. One ID # per placard.
On an orange panel near the placard. One ID # per orange panel but only one placard.
On a white square-on-point near the placard. One ID # per white square-on-point but only one placard.

In short, both of the two ID #s and at least one placard for the hazard class must be visible on all four sides of the vehicle. How you do it is up to you.

I hope this helps. Please contact me with any other questions.

That must have done it because on May 12, 2016 I received the final message:

Thank you.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/