A question 11.22.21:
Hello I have been asked to transport IBC containers containing trace (essentially empty) amounts of several types with id #1789/1790/1835/2031 am I correct in assuming they should still be identified by their numbers on the outside of my trailer even though they are in small quantities? I am in New York…
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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 |
My answer:
You are correct. A bulk packaging (e.g., IBC or intermediate bulk container) that contains even trace amounts of a HazMat is subject to full USDOT regulations. This includes but is not limited to the following:
- Placards and the HazMat’s identification number displayed on all four sides of vehicle.
- Hazard communication including labels & marks on the packaging.
Read: Hazard Communication Options on the Intermediate Bulk Container
- A HazMat shipping paper to describe the consignment.
- A commercial driver’s license (CDL) with the HazMat endorsement for the driver.
- HazMat Employee training (I provide this training).
Read: USDOT/PHMSA Regulation of Empty Packagings with Residue
Please contact me with any other questions.
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Conclusion:
Another driver with a question. I’m glad he/she contacted me and I’m glad I was able to answer their question. HazMat transportation is too important to risk a non-compliance.
Scope and Applicability:
The above answer is derived from the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).