A question from someone who had recently attended my Onsite Training (01.18.18):
I just had your DOT training this month, and I ask which placards to use when shipping our product(with a UN 3190 self heating solid). I am still having problems with drivers as to which placards to use.
Yesterday I shipped 123 drums of product each drum contains 200 lbs. This was shipped on 31 skids as a truck load at 24,600 lbs.
This is the problem:
It is my understanding that when I ship this product as a truck load I would use the placard (Spontaneously Combustible 4 )When the driver call the load in to his safety department they requested we use the placard (Spontaneously Combustible 4 with the UN 3190) on it. They would not take the load with out it. Because the amount was over 8,820 lbs it had to have the UN# on it.
So I gave the driver both types of placards. Is this right to do or not? Which placard is right to use in this case.
Thanks for any help you can give.
My reply the same day:
Good question. Please see below.
- The placard for a Division 4.2 Spontaneously Combustible is required if the total amount of all hazmat on the vehicle is equal to or greater than 454 kg (1,001 lb).
- The placard must meet the specifications for shape, design, &etc.
- Placard must be displayed on all four sides of the vehicle.
Identification number mark:
- Per 49 CFR 172.301(a)(3) a transport vehicle must display the identification number for a hazmat under the following conditions:
- Non-bulk packaging (e.g., 55-gallon drum).
- Vehicle contains only a single hazmat.
- Each package is marked with the same proper shipping name and ID #.
- Total weight of hazmat is equal to or greater than 4,000 kg (8,820 lb).
- All hazmat loaded at one loading facility.
- Transport vehicle contains no other material (hazmat or non-hazmat).
- Identification number must be displayed on all four sides of vehicle.
- Identification number may be displayed on placard or near placard on orange panel or white square-on-point.
Answer: Vehicle must display placard for Division 4.2 with identification number (3190) on or near placard. It is not necessary to provide both.