A leak of some sodium hydroxide. Seems pretty simple, right? But a close look at the picture and text of the article gives me pause. I believe there is the potential for a violation of the Hazardous Material Regulations of the PHMSA/USDOT, and it’s not the leak. Read the original article closely then see what I can discern from it. After you’ve read my article tell me if you think I got it right or not. What I intend to do here is compare the available information to the applicable regulations (the HMR) and then provide my conclusion. (more…)
While there are many different types of HazMat packaging, all of them fall into one of two categories: bulk or non-bulk. The purpose of this article is to define and explain both bulk and non-bulk packagings pursuant to the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).
An Intermediate Bulk Container (IBC) is an example of a bulk packaging.
One thing about hazardous materials that can’t be denied is that they move among us all the time. It’s the proximity of hazardous materials in commerce to people that makes adherence to the Hazardous Materials Regulations so important. Since we find hazardous materials in transportation around us frequently, it behooves us to learn more about them and the hazard communication methods. Take a look at the photo below and see if you agree with my interpretation of the regulations. (more…)
49 CFR 172.504 – General Placarding Requirements contains the applicability, scope, and general requirements for the use of placards when transporting a hazardous material. §172.504(a) identifies the five (5) types of packagings and modes of transportation that will require placards, unless excepted. A closer look at these five defined terms is important since packagings and methods of transportation not included in §172.504(a) will not require a placard. (more…)
A Bulk Packaging, defined at 49 CFR 171.8: “Means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has:
A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
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
A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.”
Simple enough, but why is it that a vessel or barge is specifically excluded from the definition of a Bulk Packaging?
Before we get to the answer, let’s make sure we understand the terms, both of which are defined at 49 CFR 171.8:
“Vessel includes every description of watercraft, used or capable of being used as a means of transportation on the water.”
“Barge means a non-self propelled vessel.”
The answer, is that any material, including a hazardous material, loaded directly into the hold of a vessel or barge is subject to the regulations of the US Coast Guard and not the Pipeline and Hazardous Materials Administration (PHMSA) of the US DOT and therefore not subject to the Hazardous Material Regulations.
The transportation of hazardous materials involves many different methods (air, water, highway, rail) each of which is subject to the regulations of the PHMSA. But other Federal agencies have their own authority and their own regulations that may impact the shipment as well. Learn what you need to know about the transportation of hazardous materials at my training, either On-Site or Public Workshop/Open Enrollment. Contact me for a free consultation on your training needs.
The placarding requirements for the transportation of hazardous materials can be very confusing. Even during my years of driving a truck for Laidlaw Environmental Services I was often in doubt about placarding requirements. I am frequently asked specific questions about placarding requirements where I must refer to 49 CFR 172, Subpart F for guidance. Additional questions arise when one must determine the placarding requirement for bulk packagings instead of transportation vehicles. 49 CFR 172.514 is the section of the regulations that deals specifically with the placarding requirements of bulk packages and is the subject of this article.
Right at the beginning – 49 CFR 172.514(a) to be exact – the regulations make clear that it is the responsibility of the shipper and not the carrier to affix (eg. stick, attach, or fasten) the required placards to a bulk packaging. This differs slightly from the placarding requirements for shipments of HazMat by highway found in 49 CFR 172.506 which require the shipper to provide the required placards to the driver of a motor vehicle (ie, carrier), but not to affix them. More about the requirement of shippers to offer placards to a driver can be found here.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
Unless an exception for your HazMat packaging is identified in the regulations (see below), it must be placarded on each side and each end – all four sides. If an exception exists for your bulk package you may use one of the following two options:
Affix the applicable placards on two opposing sides only.
Affix a HazMat Label on two opposite sides only per 49 CFR 172, Subpart E – specifically 49 CFR 172.406(e).
The excepted bulk packagings are as follows:
A portable tank with a capacity of <1,000 gallons.
A DOT 106 or 110 multi-unit tank car tank (railroad tank car designed to specifications).
Another bulk packaging – such as a bulk bag or box – with a capacity <640 cubic feet. This does not include a portable tank, cargo tank, or tank car.
If a bulk packaging is not excepted and placarding is required, then the placards must remain even when it is empty unless it –
Is sufficiently cleaned of residue and purged of vapors to remove any potential hazard.
Is refilled with a different hazardous material to such an extent that the remaining residue is no longer hazardous.
It contains the residue of a Class 9 hazardous substance below the reportable quantity and any markings, labels, or placards indicating it is hazardous are removed, obliterated, or securely covered in transportation [49 CFR 173.29(b)(1)].
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
You may read more here about the requirements for shipping empty packages of hazardous materials. You may also wish to learn much more about the Hazardous Material Regulations (HMR) of the US DOT and how they apply to you as a shipper of hazardous materials. While you’re at it you may also wish to learn more about your regulatory requirements under the US EPA as a generator of hazardous waste.
