Question (April 09, 2018):
My reply the same day:
Thank you for contacting me. I will answer your question below.
- Display of the Class 9 Miscellaneous placard is not required within the U.S.
- However, if transporting a bulk packaging the identification number (3082) must be displayed on all four sides of the vehicle unless the identification number displayed on the tote is visible during transport, e.g., the totes are loaded on a flat-bed trailer and the identification number is visible.
- I assume the contents of the tote meets the definition of a marine pollutant.
- Per 49 CFR 172.322(c) a vehicle that transports a packaging that is marked as a marine pollutant must display the marine pollutant mark (at the size of a placard) on all four sides.
- However, the marine pollutant mark is not required to be displayed if some other placard is displayed.
Options:
- Display Class 9 placard with ID number (3082) and marine pollutant mark.
- Display Class 9 placard with ID number w/o marine pollutant mark.
- Display marine pollutant mark with ID number w/o Class 9 placard.
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Conclusion:
The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) are especially tricky when the issues of marine pollutants and Class 9 Miscellaneous come up. This question dealt with both!
Another issue not addressed in this exchange – though relevant to the questioner – is the difference between domestic and international regulations for the classification of marine pollutants and the display of the Class 9 Miscellaneous placard. It is quite possible that a substance delivered to your site as a marine pollutant in a vehicle or freight container displaying the Class 9 placard may not be a HazMat at all when you offer it for transport (i.e., ship) it from your site. This is because the rest of the world classifies a marine pollutant differently than we do here in the U.S. and the rest of the world requires the display of the Class 9 placard
- USDOT/PHMSA HazMat Employee training
- IATA Dangerous Goods by Air training
- IMO Dangerous Goods by Vessel training
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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 |