A question from someone in the HazMat transportation business (06.02.17):
The company I work for hauls frac tanks recently we had a tank that was used to store red diesel heating oil when we went to pick up the tank there was a gallon or two residual left in tank are we allowed to transport the tank with residuals in it and do we need paper work and placards.
My attempt to buy some time that same day:
Please give me some time to research and provide an answer.
My reply eleven days later (06.13.17):
UN1993, Diesel fuel in an intermediate bulk container
Thank you for your patience. I will try to answer your question. Please see below.
- I assume that red diesel meets the USDOT definition of a Class 3 Combustible Liquid.
- If so, it is subject to the combustible liquid exception.
- However, a bulk packaging (e.g. frac tank) is not subject to the full combustible liquid exception.
- Unless rinsed, cleaned, & purged of all vapors, USDOT regulates a packaging with residue the same as if it was full.
- Some non-bulk packagings are subject to the empty packaging exception.
- A bulk packaging (e.g. frac tank) is not subject to the exception and if it contains any residue of a hazardous material must be transported in commerce as a fully-regulated HazMat.
- A fully regulated bulk packaging transported in commerce requires placards, shipping paper, trained personnel, &etc.
|
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 |