Before we begin…
All of the following is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).
Question (10.20.20):
You seem to have the most info and the most accurate info regarding highway transportation of hazmat. Recently I hauled this “modular power unit” from NM to NY. At the delivery point the job super asked why it wasn’t placarded, I told him I wasn’t tendered the load as hazmat, so I had no idea. He told me the unit was a battery backup for GE and contained 50,000 lbs of lithium ion batteries. Is that considered hazmat and was it supposed to be marked or placarded?
Answer (10.20.20):
Thank you for the compliment. Good question. The answer depends on many factors. See below.
- This table indicates the regulatory thresholds for lithium battery “size”. It is necessary for the classification and transport of lithium batteries.
| Status | Lithium Ion Battery
(Watt-hour (Wh) Rating) | Lithium Metal Battery
(Lithium Content (g)) |
| Battery | Cell | Battery | Cell |
| Subject to "smaller battery exception" | Does not exceed 100 Wh | Does not exceed 20 Wh | Does not exceed 2 g | Does not exceed 1 g |
| Subject to full regulation | Exceeds 100 Wh | Exceeds 20 Wh | Exceeds 2 g | Exceeds 1 g |
| Subject to "smaller battery exception" by highway or rail | Does not exceed 300 Wh | Does not exceed 60 Wh | Does not exceed 25 g | Does not exceed 5 g |
- If the lithium batteries met the criteria for “smaller” in the HMR i.e., less than 100 Watt/hour (Wh) for lithium ion or less than 2 grams of lithium metal for lithium metal battery, then it is (mostly) not subject to USDOT regulations when in transport. It would not be a “HazMat” load but each package containing a lithium battery would need to display the lithium battery mark. No other regulations would apply. Read: Classification of Lithium Batteries for Transportation in Commerce
- If the batteries were larger than indicated above (as I suspect they are), then they would be subject to full regulation as a “HazMat” shipment. However, even then it is not necessary to display placards on the vehicle.
Q: “Why is it not necessary to display placards on a vehicle transporting this quantity of lithium batteries?”
A: “Lithium batteries of all types, all configurations, and all quantities are a Class 9 Miscellaneous. The display of the Class 9 Miscellaneous placard is not required within the U.S. – though it remains an option.
Read: Is the CLASS 9 Placard Required?
- Further, since the vehicle is not required to display a placard, the driver is not required to have the HazMat endorsement on their CDL.
- However, if this is a fully-regulated HazMat shipment as I suspect, you should have been provided with a shipping paper describing the consignment and been given emergency response information and an emergency telephone. Also, you must receive HazMat Employee training.
- If you are able to provide more information about the batteries I can provide more specific information.
- At a minimum you should have HazMat Employee Training.
Please contact me with any other questions.
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Contact me with any questions you may have about the transportation of lithium batteries by air, highway, vessel, or rail
International and Domestic
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That did it!
The transportation of lithium batteries is essential and complicated. Make sure you comply with the Hazardous Materials Regulations of USDOT/PHMSA for any transportation to, from, or through the U.S.
A simple question on April 18, 2o18:
My question: is a specific Id# and placards required on a trailer for a class 9 portable tank/tote bin shipment?
Thanks
My reply:
Thank you for contacting me. I will try to answer your question. Please see below.
- The Class 9 Miscellaneous placard is not required to be displayed on a bulk packaging (e.g., a portable tank or tote bin) or a transport vehicle within the U.S.
- The Class 9 placard may be displayed if desired by the carrier. All regulations pertaining to the display of placards then apply.
- If the Class 9 Placard is not displayed on a bulk packaging, the packaging must then display the required Class 9 Miscellaneous label.
- The 4-digit identification number of a HazMat must be displayed on a bulk packaging (e.g. portable tank or tote bin) of a hazardous material.
- If the identification number on a bulk packaging in or on a vehicle or freight container is not visible during transportation (e.g. the tote bin is inside the cargo hold of the vehicle) the identification number must be displayed on all four sides of the vehicle or freight container.
- Many times the HazMat’s identification number is displayed on the Class 9 placard, though it is not required to be. It may also be displayed on an orange panel or on a white square-on-point. Any of the following is an acceptable display of the identification number for a Class 9 Miscellaneous HazMat.
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White Square-on-Point
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Placard
I hope this helps. Please contact me with any other questions.
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Interested in site specific training at your site that covers this topic, and more!
Ask me about my Onsite Training
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Conclusion:
The job of a driver transporting hazardous materials on a public roadway is not easy. Regulations like this can make it even harder. Make sure you – or your drivers if you represent the motor carrier – are trained and knowledgeable in the regulations of USDOT/PHMSA for the transport of hazardous materials.
Pretty simple question from December 4, 2017:
I’m hauling UN2211 class 9 Polymeric Beads 44K lbs
Do I need to be Hazmat Endorsed as a Carrier to haul this?
Pretty simple answer:
No. The Class 9 placard is not required to be displayed on a motor vehicle within the U.S. Read: Is the class 9 placard required?
However, if you are transporting a bulk packaging (read: Bulk Packaging for HazMat Explained!), you must display the identification number (2211) on all four sides of the vehicle. You MAY choose to display the identification number on the class 9 placard.
Since the Class 9 placard is not required to be displayed, you are not required to have the HazMat endorsement on your CDL. The HazMat endorsement is only required if you transport a quantity of HazMat that requires the display of placards.
However, if you transport any quantity of HazMat you must have HazMat Employee training to include a component on safe driving.
I hope this helps. Please contact me with any other questions.
His reply:
Thank you for the clarification. Basically I’m not Hazmat Endorsed. My drivers are not Hazmat certified. But because it’s a UN2211 Class 9. Then we can still haul it even though it’s over 2,000 LBS.
My clarification:
Yes. That is correct.
- Placards are not required for Class 9 in the U.S. no matter the amount.
- The HazMat endorsement on the CDL is only required if the vehicle transports a quantity of HazMat that requires placards.
- However, HazMat Employee training is required for anyone involved in the transportation of a hazardous material – even Class 9.
- An additional component of Driver Training should be added to HazMat Employee training.
- Also, though terms such as “Hazmat Endorsed” or “Hazmat certified” are used in the industry, they don’t exist in the regulations. The regulations of the Federal Motor Carrier Safety Administration (FMCSA) refer simply to the HazMat Endorsement on the Commercial Driver’s License (CDL).
