A question from November 12, 2017:

“tanker trailer” referred to in the hazardous materials regulations as: cargo tank

Hello, I just bought a tanker trailer and the seller said it was last used to haul non hazmat. The companies that want to transport it to me are asking for a wash ticket and that it be purged. Do I need to do that?

My reply the next day (11.13.17):

Thank you for contacting me. I will try to answer your question below.

• The regulations of the USDOT do not require a wash/purge ticket for a packaging that contained a non-hazardous material. Non-HazMat are not subject to DOT’s Hazardous Materials Regulations.
• The vehicle and trailer may be subject to other DOT regulations for licensing &etc.
• If the trailer contained the residue (even vapors) of a hazardous material then it must be transported as one of the following:
  • A fully regulated HazMat: shipping paper, placards, HazMat Employee training, HazMat endorsement on driver’s CDL…

Or…

• • Rinsed & cleaned & purged of all vapors so no hazard remains. In this case it can be shipped as non-HazMat.
• A wash or purge ticket or certificate is not required to achieve the above. If you as the shipper are willing to certify that no hazard remains then it can be shipped as non-HazMat.
• Of course, the carrier can always reject your certification and demand more – such as a wash/purge ticket – but it is not required by regulation.

In sum: you are not required to provide a wash/purge certificate in this case but you may need to or else find another carrier.

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

His reply that day (kinda’ made all of my work for naught!):

Thank you for the clarification. I did go to the company that sold me the vehicle and I did receive a purge ticket. The carrier that wants to transport my trailer to me wanted one. I just wasn’t sure. Thanks for the info again.

Conclusion:

I’m glad that it all worked out for this person.  This type of situation is not uncommon in the HazMat transportation industry; someone insists on something not required by the regulations.  Your options are either to “push back” and ask them to cite the regulations they are using as justification for their claim or meekly go along with their demands.  (I don’t intend to disparage the meek, they help to get a lot of things done.)

For more information on this topic read: Emptying a Hazardous Material Packaging