A follow-up question from a occasional contact (06.13.18):
Daniel, Hope all is doing well.
I have another question that has been bothering me as well. Hoping you can share some guidance.
Say I have a shipment of UN1993 BULK(ONE TOTE BIN)
I also have a shipment of Corrosive UN1806 non-bulk weighing 500lbs.
No other hazmat on board. How would this trailer be placarded?
I, myself would say a bulk UN1993 placard and a corrosive placard.
I have had other safety officials advise that the bulk shipment is not included on the aggregate gross weight once its placarded.
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My reply several days later:
I have an answer and it is not what I initially anticipated (I’m glad I did additional research of 49 CFR 172.504(c)). Please see below.
- When determining the placarding requirements for a vehicle there are three criteria to consider (other exceptions are available but not applicable to this scenario):
- Is it any quantity, any packaging of a HazMat identified in Table 1 at §172.504(e)? If so, placard for hazard class.
- Is it any quantity of HazMat identified in Table 2 at §172.504(e) in a bulk packaging? If so, placard for hazard class.
- Is it any single or multiple HazMat of an aggregate gross weight of 454 kg (1,001 lbs) or more ? If so, placard for each hazard class.
- The above criteria are considered independently. Therefore, the weight of a Table 2 HazMat in a bulk packaging (which requires display of the placard for its hazard class according to #2 of the above) is not counted toward the aggregate gross weight threshold indicated in #3. Similarly, the weight of a Table 1 HazMat (placards required according to #1 of the above) is not counted toward the aggregate gross weight threshold of #3.
- Separate from the regulations for the display of placards are those that require the display of the identification number on transport vehicles and freight containers. A vehicle transporting a bulk packaging (e.g., an intermediate bulk container or tote bin), must display the HazMat’s identification number unless the number is visible on the packaging during transport.
In your scenario the vehicle must display the Class 3 placard with the identification number (1993) – because it is in a bulk packaging – but not the Class 8 placard – because it’s gross aggregate weight (not counting the Class 3 tote) is <454 kg (1,001 lbs). Of, course, the driver has the option to display the Class 8 placard if they so choose.
This letter of interpretation from USDOT/PHMSA almost exactly represents your scenario: LOI 02-0043.
I hope this helps. Please don’t hesitate to 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 |
And that did it.
The regulations for the display of placards on a vehicle can be simple, but can become more complex when the hazardous materials transported and the types of packagings used increase. Make certain your placards are correct and are displayed properly.