A question from a shipper or carrier of HazMat (07.31.20):

I am hauling NA 1993 combustible liquid pg3 (2-methyoxymethylethoxy propanol) in a tote of 350 gallons. Its total weight is 2329lbs. This is the only hazmat on the truck.

*bulk haz. Mat placard accordingly*

Do I need to put UN number on the truck? Could you help me when is to put un number onto placards? Your help would really be appreciated.

Thanks

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My reply that same day:

I will try to answer your question below.

• You indicate your HazMat is a Class 3 Combustible Liquid.
• I understand the HazMat is contained and transported in a bulk packaging (i.e., has a capacity of more than 119 gallons).
• More specifically, the packaging is a tote, which I presume to be an intermediate bulk container (IBC).
• The HazMat Regulations for the display of labels, marks, and placards on an IBC are complex. Read: HazMat Labels, Markings, and Placards on an Intermediate Bulk Container
• A vehicle transporting a bulk packaging of a HazMat must display both of the following on all four sides of the vehicle or freight container:
  • The placard (in this case the Class 3 Combustible Liquid).
  • The identification number (in this case NA1993). It is displayed solely as “1993” it is not necessary to include the “NA”.
• The identification number can be displayed in any one of three ways:
  • On the placard. (The white in the bottom of the placard is an option and is not required.)

 

• • On an orange panel near the placard.

 

• • On a white square-on-point near the placard.

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

He wanted some more information:

Thank you for the information. Could you please tell me more when to include UN number. I always have same issue number of times.

Thanks in advance.

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I had the information:

Sure:

Any time you have a hazardous material in a bulk packaging (>119 gallons), the identification number must be displayed on all four sides of the vehicle.

• This is true if the vehicle itself is a bulk packaging, such as a cargo tank or portable tank.
• Or, if the bulk packaging – such as an intermediate bulk container (IBC) – is loaded on a vehicle. Unless the identification number displayed on the bulk packaging is visible while in transportation. Read: Q&A: When transporting IBCs, must the identification number be displayed on the vehicle?

Also, the identification number must be displayed on a vehicle if it contains a large amount of a single HazMat in a non-bulk packaging. Read: Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings

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 Info@DanielsTraining.com https://www.danielstraining.com/

That seemed to do it!

Thanks a lot.

Conclusion:

The Hazardous Materials Regulations of USDOT/PHMSA are a challenge for both shippers and carriers of HazMat. If you have a question, contact me. If you need HazMat Employee training, contact me!