A question from a recent customer (June 06, 2018):
Daniel,
Hope this finds you well. I am the warehouse manager at <<Company>>. I was wondering if you can clear something up for us. When placarding trucks if we have multiple hazard classes shipping and it is over 1000# we have to placard all the hazard classes correct? If you look at the attachment I believe we should’ve placarded both class 8 & 9. (A shipping paper was attached showing a consignment of more than 2,500 lb of various Class 8 Corrosive Materials, more than 3,000 lbs of a Class 9 Miscellaneous, 220 lb of a Class 3 Combustible Liquid, and some non-hazardous materials). I have some that believe if one class is over the 1000# that is what gets placarded. Would you be kind enough to help clear this confusion.
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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 reply:
Thank you for contacting me. Based on the available information I have made the following determination. Please see below.
- The consignment contains both HazMat & non-HazMat. The non-HazMat is not counted toward the placarding threshold.
- The HazMat is of three types: Class 8 Corrosive, Class 9 Miscellaneous, & Class 3 Combustible Liquid.
- All are in a non-bulk packaging.
- 49 CFR 172.504(a) indicates it is necessary to display placards on a vehicle containing any amount of a hazardous material except in the following conditions:
- A hazardous material identified in Table 2 of the placarding tables at §172.504(e), in a non-bulk packaging, if the total amount of HazMat in the vehicle is less than 454 kg (1,001 lb).
- Since neither the Class 9 Miscellaneous nor the Class 3 Combustible Liquid in a non-bulk packaging are required to display placards, their respective weight is not counted toward the placarding threshold.
- This letter of interpretation from USDOT/PHMSA (97-0099) is too old to be available as a link from their website. However, it indicates that Class 9 Miscellaneous HazMat is not counted toward the placarding threshold: “Only materials that are covered by Table 2 and that require placarding are included in the aggregate gross weight.” Though not stated directly, this would apply to Class 3 Combustible Liquids in a non-bulk packaging as well.
- Read: Is the Class 9 Placard Required?
- Read: USDOT Exception for Combustible Liquid HazMat
- If the weight of the Class 8 Corrosive is 454 kg (1,001 lbs) or more, then it is necessary to display the Class 8 Corrosive placard on the vehicle.
- Display of the Class 9 Miscellaneous and the Class 3 Combustible Liquid placards on the vehicle are optional – at the discretion of the driver – but not required.
I hope this helps.
Please contact me with any other questions.
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And that did it!
This absolutely helps. Thank you for this info.