Q&A: What hazard communication (marks, labels, & placards) are required on a bulk packaging and a vehicle transporting a bulk packaging?

Question3:

“next question if I have a bulk container that requires a un number but I also have non bulk waste under the same un number do I have to placard my trailer with both the un number and a class placard or will the un number cover both.”?

Answer3:

Both the placard and identification number must be displayed on the vehicle.
If the identification number displayed on a bulk packaging is not visible in transportation, e.g., it is inside a cargo trailer, then it is necessary to display the identification number on all four sides of the vehicle.
A bulk packaging containing any amount of any HazMat requires the vehicle to display the applicable placard for the HazMat on all four sides of the vehicle.
In this case the vehicle must display the identification number and the applicable placard for the HazMat in the bulk packaging. This can be displayed in one of three ways:
- The identification number may be displayed on the placard.
- The identification number may be displayed near the placard on an orange panel.
- The identification number may be displayed near the placard on a white square-on-point.

If an identification number is displayed on a vehicle it must represent all of the HazMat of that Class in the vehicle. Since you indicate you have a bulk and non-bulk packaging of the same identification number, a placard representing the Class and the identification number must be displayed on all four sides of the vehicle. Read: When not to Display and ID# on a Vehicle

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

Conclusion:

A tough question because the inquisitor started with an incorrect understanding that its OK for a 55-gallon drum to weigh more than 882 lb – it’s not!

Sometimes knowing the right question to ask requires a basic understanding of the USDOT/PHMSA Hazardous Materials Regulations. My monthly HazMat Employee Training Webinars can do just that.

Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?

Question:

If I have a single 55 gallon drum that weighs over 882 lb is it considered a bulk Wait! Stop! That question contains a false premise. I can’t consider the next question until I explain a bulk packaging and the limits on the maximum net mass of a 55-gallon drum. The next question will have to wait for another article.

Answer:

Thank you for contacting me. Please allow me to provide some clarification on the term “bulk packaging”.

A bulk packaging is defined at 49 CFR 171.8 in the Hazardous Materials Regulations (HMR).
It reads in part:

…a bulk packaging has: * * *

(1) A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;

(2) A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or

(3) A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.

emphasis added.

Read: Bulk Packaging for HazMat Explained!

You do not state whether the HazMat in the drum is a liquid or solid – I presume it is not a gas – but, regardless, the maximum capacity of a bulk packaging must be greater than 450 L (119 gallons) for both a liquid and a solid HazMat.
It is interesting to note that a bulk packaging for a solid must have a maximum net mass of greater than 400 kg (882 lb) AND a maximum capacity greater than 450 L (119 gallons).
You indicate it is a 55-gallon drum. Therefore, its maximum capacity is 208 L. This can’t be a bulk packaging.
You also write it weighs more than 882 lb (400 kg). Since this is the gross mass (weight of packaging and HazMat), I will presume the net mass (weight of the HazMat only) is also greater than 400 kg (882 lb); regardless, this is not enough to meet the criteria of a bulk packaging. *It is – in fact – a violation of the packagings specification and will be addressed later*

In sum: What you describe is a non-bulk packaging because its maximum capacity is well below the threshold required for a bulk packaging.

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Now, how about that 55-gallon drum weighing more than 882 pounds?

A 55-gallon drum used for the transportation of a HazMat must be designed, manufactured, tested, & marked to meet a specification acceptable to USDOT/PHMSA.
I presume the specification in use here, as in most transport of HazMat in non-bulk packagings and IBCs, is the United Nations Performance-Oriented Packaging Standards (aka: UN Standard). The requirements for this specification are found at 49 CFR 178, subpart L.
These regulations specify limits on the maximum capacity of all drums made to the UN standard; they are:

Drum Type	Maximum Capacity	Maximum Net Mass
Steel drums	450 L (119 gallons)	400 kg (882 pounds)
Aluminum drums	450 L (119 gallons)	400 kg (882 pounds)
Metal drums other than steel or aluminum	450 L (119 gallons)	400 kg (882 pounds)
Plywood drums	250 L (66 gallons)	400 kg (882 pounds)
Fiber drums	450 L (119 gallons)	400 kg (882 pounds)
Plastic drums	450 L (119 gallons)	400 kg (882 pounds)

A plywood drum?!?

As you can see from the table, no drum of any composition made to the UN Standard may exceed a maximum net mass of 400 kg (882 lb).
If you have a 55-gallon drum that exceeds a maximum net mass of 882 pounds, it is a violation of the HMR at 49 CFR 173.22(a)(2) for the shipper to offer it for transportation to the carrier.
It is a violation of the HMR at 49 CFR 177.801 for the carrier to accept a consignment containing a 55-gallon drum that exceeds a maximum net mass of 882 pounds.

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

Daniels Training Services, Inc.

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Conclusion:

He didn’t contact me with any follow-up questions. However, read here for the article that answers the question he posed after this one.

Q&A: What hazard communication is required on an IBC filled with aerosol cans transported for recycling?

June 11, 2020:

Daniel

I have read your Bulk Packaging for hazmat. I have a questions regarding the aerosol cans packed in an 11G fiber cubic yd boxes (aka: an intermediate bulk container or IBC). You have confirmed placards and UN numbers are not required due to inner containers. If boxes do display placards 2.1 with the 1950 across in the white panel would this be a violation for over placarding?

Thanks for your help.

My reply the same day:

Thank you for contacting me. I will try to answer your questions. Please see below.

I presume you are referring to the following Q&A at the end of the article:

Q: Are aerosol cans loaded in a UN specification bulk packaging, i.e. an 11G fiberboard Intermediate Bulk Container (IBC) subject to the marking, labeling and placarding requirements for a bulk packaging?

A: No. The definition of a bulk packaging specifies that it must contain hazardous materials that are loaded with no intermediate form of containment. The aerosol cans in the 11G box would be a form of intermediate containment and, thus, not considered a bulk packaging. It is interesting that in this situation what may start as a bulk packaging may not continue to meet the definition depending on how it is used.

As a rule, using hazard communication in excess of what is required, as long as the HazMat is present and other conditions are met, is not a violation.
I will need more information about your situation: Are the aerosols in this case being transported as a waste for disposal or recycling?

Please advise.

Some more information on June 11, 2020:

Thanks Daniel for helping me.

I did call the DOT hotline and since the cubic yard box is acting as on overpack for the aerosol cans the placard with the UN number across the middle would not apply. I looked at Large Packaging requirements which do contain inner containers but the 11G IBC does not meet the requirements of a Large packaging since it does not exceed 119 gallons.

We are shipping these for disposal (hazardous waste).

We normally have the yellow haz waste marking with all the generator information, shipping description etc and a 2.1 placard with 1950 across the middle on two opposite sides of the IBC. Would this still be acceptable by DOT or a violation?

Thanks so much for your help.

Interested in site specific training at your site that covers this topic, and more!

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Still June 11th, my reply:

I will do my best to answer your question and provide guidance. Please see below.

I believe the Q&A in my article on bulk packaging & your call to DOT confirms the cubic yard box with aerosols is not a bulk packaging. Therefore, it could display the labels and marks as if it is a non-bulk packaging.
Non-bulk packagings must be display labels in compliance with 49 CFR 172, subpart E.
A placard with the ID # displayed on it will not meet the specifications of a label. I believe it would be a violation to display the placard instead of the required label.
However, it is not a violation to use hazard communication in excess of what is required as long as the hazard is present. You could display the placard in addition to the label, but not in place of it.
There is a good exception from full regulation for aerosols shipped for disposal or recycling at 49 CFR 173.306(k). Using it makes discussion of labels and placards on the cubic yard box unnecessary.

Also…

It didn’t come up in this Q&A, but check to see if your state has adopted the USEPA’s Final Rule including aerosol cans as a universal waste.

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

Daniels Training Services, Inc.

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And, the next day, her final reply:

Thanks for your help. I start confusing myself when reading and rereading the requirements.

Conclusion:

There’s no shame in admitting you may become confused by the regulations (it happens to me all the time). The solution is to sit down and carefully review the regulations, guidance documents, and interpretation letters of the respective agency until you can finally make sense of it all. Or call me.

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Q&A: Are my 100 lb fiber drums a bulk packaging?

A question received February 01, 2018:

Hello Daniel,

I am contacting you with a question on the bulk/non-bulk classification. I work for a company that ships explosives in fiberboard drums. These drums hold no more then 100lbs but they are shipped in a tractor trailer unit that can hold up to 42,000 lbs. I am not sure if this is a bulk packaging with the fiberboard drums being an intermediate container or if it is considered non-bulk packaging because the only amount that is considered is the amount put in one fiberboard drum.

Any help on this matter would be great!

Best Regards,

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My reply February 12, 2018:

Thank you for contacting me. Please see below.

The packaging you describe (fiberboard drums of no more than 100 lbs) are a non-bulk packaging. They do not meet the definition of a bulk packaging. Read: Bulk Packaging for HazMat Explained!
The tractor trailer unit is the transport vehicle – more specifically: the motor vehicle since it is used for transportation by highway – for the HazMat packagings. It is not a bulk packaging.
The only type of bulk packaging that contains an intermediate form of packaging is the large packaging which is not what you describe.

I hope this helps. Please don’t hesitate to contact me with any questions. I have provided training and consulting services for others in the ordnance/explosives industry in the past.

Daniels Training Services, Inc.

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: 30-gallon drum = non-bulk packaging

: Composite IBC

: Transport Vehicle (aka: Motor Vehicle)

Q&A: Are Forty 55-gallon drums on one truck considered to be bulk?

Just a quick question June 19, 2018:

Is carrying 40 – 55 gallon drum of NaOH on a box trailer considered bulk?

Sent from my iPhone

My reply just an hour later:

No it is not.

Please see below for an explanation:

A bulk packaging is one with a capacity of greater than 119 gallons. Read: Bulk Packaging for HazMat Explained!
Your containers are 55 gallons each.
The total volume of the shipment is not a factor.
You may, however, need to display the identification number for the hazardous material on the vehicle.
- Read: Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings
- Read: Display of the Identification Number on Transport Vehicles and Freight Containers

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Her gracious reply:

Thank you. That’s what I thought but just wanted to make sure.

I wasn’t done (I have so much to share!):

You’re welcome!

You may wish to read this article I wrote indicating when it is necessary to display the identification number on a transport vehicle if it contains a large quantity of a single HazMat: Vehicle Marking Requirements for Single HazMat.

That spurred another question (06.20.18):

I read the other article you sent and it did clear up when to use numbered placards on a straight forward shipment. Other scenarios would also be helpful.

What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?
Same scenario but you picked them up from two separate shippers?
Another: Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?

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My reply the next day:

I will attempt to answer your questions below.

Scenario 1: “What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?”
- Answer: In this scenario you must display the applicable placards for each HazMat unless one of the placarding exceptions at 49 CFR 172.504(f) apply. If both HazMat are in a non-bulk packaging you must not display the identification number. If either of the HazMat are in a bulk packaging you must display its identification number on or near the placard.
Scenario 2: “Same scenario but you picked them up from two separate shippers?”
- In this scenario the vehicle would display the applicable placard and identification number for the first shipment (assuming all of the other conditions of 49 CFR 172.301(a)(3) are met). When the second shipment is picked up the placard for the second HazMat must be displayed, but not its identification number. The identification number and placard from the first shipment would continue to be displayed (this is based on a conversation with the HazMat InfoLine. It is not clear from the regulations. I could not find a letter of interpretation to confirm).
Scenario 3: “Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?”
- If both HazMat picked up from one shipper then Scenario 1 from above will apply.
- If picked up from two separate shippers then Scenario 2 will apply.

I hope this helps. Please don’t hesitate to contact me with any other questions.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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That seemed to answer all of his/her questions.

I frequently receive questions about placarding vehicles. As you can see from this Q&A, there are many scenarios to consider and each may require a different display of placards. If you are a carrier of HazMat, make certain you display the correct placards. If you are a shipper of HazMat (i.e., you offer the HazMat to a carrier for transport), make certain you offer the correct placards to the driver.

As a shipper or a carrier, make certain all of your employees with a direct affect on the safe transport of HazMat receive initial and triennial HazMat Employee training.

Q&A: How do I classify a Class 3 Combustible Liquid for both international and domestic transport?

This e-mail was sent from a contact form on Daniels Training Services (https://danielstraining.com) on December 05, 2019

Hello,

I am trying to name a chemical for transport. It has a flashpoint of 81 C. It is not a US DOT marine pollutant, but it is an IMDG marine pollutant. We ship in both bulk and non-bulk packaging, both domestically and internationally. I believe the US DOT name would be NA1993, combustible liquids, n.o.s. (name), 3, III -is that correct?

I am having a hard time with the IATA and IMDG name. Would those still be the NA1993? I know that NA1993 isn’t recognized internationally, so I am little confused as how this should be named. Any help you can provide with the naming would be greatly appreciated!!

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My reply December 10th:

Thank you for contacting me. I apologize for my delay. I will review and reply. Please advise on the below.

What is the chemical? Do you have an SDS?
What makes it an IMDG marine pollutant?
What is the expected capacity of the packaging: <5 L / 5 kg? <119 gallons? >119 gallons?
Does transport begin or end in the U.S.?

Thank you and please advise.

Answer:

Hello Daniel,

Thanks for taking the time to help me with this!!

The product is a blend of basic epoxy resin (casRn 25085-99-8) and Oxirane, 2-(butoxymethyl)- (casRn 2426-08-6); flash point 81 °C
No, we do not have a SDS. We are trying to make one and the SDS author asked me to assist in the naming.
It is IMDG marine pollutant because it meets the UN model regulation criteria for classification as a Chronic Aquatic Toxicity Cat 2.
When we make a SDS, we include the names for each package type and mode of transport. We ship 1L to 20L/5 gallon samples, 55 gallon drums, and 275 gallon totes
- 1L to 5 gallon samples ship by ground or air both domestically and internationally
- 55 gallon drums and 275 gallon totes ship by ground domestically and by vessel internationally
Transport begins in the US

Thanks,

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It was after Christmas, (12.27.19) but I got him an answer:

I will try to answer you questions. Please see below.

Based on the flash point it is a Class 3 Combustible Liquid per USDOT regulations.
A material with a flash point higher than 60 degrees C is not subject to international regulations (IATA or IMO).
Based on your information it is not a marine pollutant per USDOT regulation but is a marine pollutant per international regulations.
A combustible liquid is not subject to USDOT regulation if transported by highway or rail within the U.S. and in a non-bulk packaging (and other conditions).
A non-bulk packaging of this material is not subject to USDOT regulations within the U.S. In a bulk packaging it is a Class 3 Combustible Liquid. NA1993, combustible liquids, n.o.s. (name), 3, III may be the proper shipping description if a more specific name is not available. There may be other shipping names that are more descriptive of the HazMat.
The material is subject to international regulation as a marine pollutant unless subject to the marine pollutant exception (packaging of less than 5 L or 5 Kg).
USDOT regulations allow a non-HazMat to be classified as a marine pollutant within the U.S. if subject to international regulation as a marine pollutant.

Also:

Section 14 of the SDS is not required to be completed within the U.S.

My suggestion:

Classify as marine pollutant for all transport.
Classify as Class 3 Combustible Liquid only when in bulk packaging within the U.S. All other transport is non-HazMat.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Read:

I hope this helps. Please don’t hesitate to contact me with any other questions.

His reply December 30th:

Thanks Daniel! This was very useful!!

Q&A: Is my tote a bulk packaging? Is it subject to regulation when shipped empty?

A question from a former coworker on August 29, 2017:

Good morning Dan. We have a client that has soaps coming to the facility that are corrosive in totes. They have contracted a recycling service to come pick up the empty totes. The service provider is being very conservative and wants to ship the totes as hazardous material, even though the totes are empty by normal practical means. They are stating the totes are 150 pounds each so when over six are shipped they are asking the client to provide placards for the shipment. The client is not DOT registered, they normally do not offer hazardous substances for transportation. Does the client take on liability for misrepresenting the shipment? (should not be shipped as a hazardous substance) I assume they would need to become registered and pay the annual fee, correct? If they only ship six totes (900 pounds), they would not require placarding and therefore would not need to be registered. However, if the transporter still wants to ship with a placard, could the client be responsible for misrepresenting the load by providing placards and signing shipping papers? Where is this addressed in the rules?

My reply that same day:

Thanks for contacting me.

Unless, “sufficiently cleaned of residue and purged of vapors to remove any potential hazard…” the packaging is subject to full regulation as a hazardous material when offered for transportation. Read: “Emptying” a Hazardous Material Packaging. 49 CFR 172.514(b) states this clearly for a bulk packaging.
There is an exception from full regulation for “empty” packagings that contain HazMat residue. However, this exception does not apply to a bulk packaging. I assume the “tote” you refer to is a bulk packaging. Read: Bulk Packaging for HazMat Explained!
Therefore, a bulk packaging containing any residue of a hazardous material must be shipped as a fully regulated HazMat. This means that HazMat labels, marks, and/or placards are required on the packaging and on the vehicle as applicable. A shipping paper describing the hazardous material must accompany the shipment. All personnel involved in its off-site transportation must receive HazMat Employee training.
Any amount of a HazMat in a bulk packaging requires the display of placards on the vehicle. It does not matter the weight of the HazMat nor the number of bulk packagings. 49 CFR 172.504(c) offers an exception for display of placards on a vehicle but not for bulk packagings or the really nasty HazMat of Placarding Table 1 at 49 CFR 172.504(e).
The shipper is responsible for the classification and shipment of the HazMat in compliance with the Hazardous Materials Regulations. They will get the fine, not the carrier.

Options:

Ship empty totes as fully regulated HazMat.
Rinse out totes so no hazard remains. Discharge wastewater down drain to POTW. Then offer for transport. No hazardous residue = no HazMat regulations.
Add chemical and/or absorbent to totes to neutralize Class 8 Corrosive. No hazardous residue = no HazMat regulations.

Hope this helps. Please contact me with any questions.

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It may not have been the answer he was hoping for but it did help:

Thank you so much Dan. I didn’t realize the totes were considered bulk packages and the “empty” definition does not apply. I’ve not really worked much with totes and I have learned something new again.

This really helps. Thank you.

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Q&A: Markings on a Bulk Packaging (Roll-off)

Another question through the Contact Me page of my website on April 3, 2016:

Dear Daniel,
A bulk container (rolloff box) requires to display the UN number in the sides?
Best Regards

My reply the next day (4.4.16):

Yes. Pursuant to 49 CFR 172.302(a), a bulk packaging must display the identification number on all four sides if it has a capacity of 1,000 gallons or more and on two opposing sides if it has a capacity of less than 1,000 gallons.

Pursuant to 49 CFR 172.302(b), markings on a roll-off must have a width of at least 0.24 inch and a height of at least 2 inches.

I hope this helps.

Please don’t hesitate to contact me with any other questions.

Here’s some more information on this topic:

What is a bulk packaging?

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Q&A: Bulk Packaging for a Compressed Gas

Often I get questions from people who are not customers. Though perhaps they will be customers in the future.

Hello

I came across your website and found the content to be very informative. I do have 1 question about bulk packages (I assume he read my blog article about Bulk Packaging for HazMat transportation). Can you further define the 3rd part of the bulk package definition? (3) A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.
Isn’t that a 119 gallon container? But how does that relate to gas?

Thanks for your time

My reply that same day:

That’s a really good question and one I struggled with when a customer of mine wanted to know the proper methods for shipment of compressed gas cylinders of Oxygen. Here is what I know about bulk packaging for a gas from researching the regulations and speaking with PHMSA/USDOT:

It applies to a gas as defined at 49 CFR 173.115, which includes the following:
- Division 2.1 (Flammable gas)
- Division 2.2 (non-flammable, nonpoisonous compressed gas—including compressed gas, liquefied gas, pressurized cryogenic gas, compressed gas in solution, asphyxiant gas and oxidizing gas)
- Division 2.3 (Gas poisonous by inhalation)
- Non-liquefied compressed gas
- Liquefied compressed gas
- Compressed gas in solution
- Cryogenic liquid
- Refrigerant gas or Dispersant gas
- Adsorbed gas
The threshold amount for a gas (>454 kg or 1,000 pounds water capacity) is based on an estimated density of water of 8.403 lb/gal: 119 gal x 8.403 lb/gal = >1,000 lbs water capacity.
You are correct that a bulk packaging for a gas (as defined at 49 CFR 173.115) has a maximum capacity of >119 gallons – the same as for a liquid.
The definition of a bulk packaging for a solid also includes a threshold amount of >119 gallons, so clearly, this is a value used uniformly throughout the definition of a bulk packaging no matter the phase of the HazMat (liquid, solid, or gas).

Cargo Tank Truck of Compressed Gas I hope this helps. Please don’t hesitate to contact me with any questions.

His reply of gratitude and a good observation.

Daniel
Thanks for the quick response.
There is so much info out there so if you don’t travel with bulk quantities of material everyday it is tough to be sure we are in compliance.

Now I had a question for him.

Thank you for your cooperation.

One more thing, you may know this better than I, but I understand that it is unlikely to find a USDOT-approved compressed gas cylinder that meets the definition of a bulk packaging. Most gases if transported in a bulk packaging will either be in a cargo tank or portable tank. Is that your understanding as well?

Thank you and please advise.

Dan

And now he gave me some good advice.

Based on presentations and interaction with DOT enforcement offices and State Troopers, I believe you are correct. They mentioned something about older bulk containers being grandfathered in to the newest rules (like propane trucks?).
I didn’t pay much attention to it because we typically don’t get into it in our business. I have been told by our Mechanical Department that the 1 bulk compressed gas package we use is acceptable as long as we have a CDL holder with haz mat and bulk endorsements and the shipping papers/manifest to go with it.
I get the impression that the rules are interpreted differently from officer to officer too. There is just too much for 1 person to be an expert on.

I was grateful for his information and had an observation of my own.

While your Mechanical Department may be right, the packaging still must be authorized for the HazMat per column 8 of the Hazardous Materials Table and meet either the USDOT specifications for a compressed gas cylinder or the UN specifications for a pressure receptacle. Or, it could be subject to a Special Permit in which case neither may be necessary.

You are correct that it can be very confusing and you can hear different opinions from different people. That is why I always rely solely on the regulations and not what people tell me. If someone tells you something regarding compliance, they should be able to back it up by citing the applicable regulation.

Please don’t hesitate to contact me if you have any questions.

Dan

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