Question:

If our shipments never require placards do we need to have placards available?

Answer:

That’s a good question. Please see below.

• The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety administration within the U.S. Department of Transportation (USDOT/PHMSA) require the shipper to provide placards to the driver unless the motor vehicle already displays the required placards. [49 CFR 172.506(a)]
• A shipper that offers hazardous materials (HazMat) for transportation in quantities that require the display of placards on the vehicle should therefore have a supply of the applicable placards in order to be able to provide them to the carrier if necessary.
• Nowhere does the HMR require the shipper to maintain a supply of placards.
• I have read of a shipper fined because it did not have a supply of placards for the HazMat they shipped. Unfortunately, I don’t have documentation for this.
• If you do not ship any HazMat that requires the display of placards, then you will never be required to provide placards to the driver and therefore you are not required to maintain a supply of them.
• Also, the requirement to provide placards to the driver at 49 CFR 172.506(a) applies solely to the HazMat you offer for transport, not to the combination of your HazMat and what is currently or will later be loaded on the vehicle.

• Note: even though the consignment does not require the display of placards, the requirement to provide HazMat Employee training for personnel with a direct affect on its safe transportation remains.
• In conclusion: No. A shipper is not required to maintain a supply of placards regardless of whether or not it may offer for transport a type or quantity of HazMat that requires the display of placards.

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