dangerous placard

Q&A: Is it necessary to display placards if I’m hauling 2,205 lb of just one type of HazMat (Division 2.2)?

Question1:

Hello,

I was hoping to get some clarification on this. I have highlighted the section in red that I am questioning. If I have less than 2,205lbs of just one type of hazard identified in table 2, non-flammable gas 2.2 to be exact, then it doesn’t need to be placarded? Or does it if it is over 1,001 lbs? It seems like the 1,001 lbs rule applies if you are combining 2 or more hazards identified in table 2?

https://www.govregs.com/regulations/49/172.504

(b) DANGEROUS placard. A freight container, unit load device, transport vehicle, or rail car which contains non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of this section may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in table 2 of paragraph (e) of this section. However, when 1,000 kg (2,205 pounds) aggregate gross weight or more of one category of material is loaded therein at one loading facility on a freight container, unit load device, transport vehicle, or rail car, the placard specified in table 2 of paragraph (e) of this section for that category must be applied.

(c) Exception for less than 454 kg (1,001 pounds). Except for bulk packagings and hazardous materials subject to § 172.505, when hazardous materials covered by table 2 of this section are transported by highway or rail, placards are not required on

(1) A transport vehicle or freight container which contains less than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by table 2 of paragraph (e) of this section; or

(2) A rail car loaded with transport vehicles or freight containers, none of which is required to be placarded.

Answer1:

Thank you for contacting me. I will try to answer your question below.Dangerous placard

  • The text highlighted in red applies to two separate placarding scenarios.
  • 49 CFR 172.504(b) applies to the use of the DANGEROUS placard.
  • §172.504(c) is an exception from the general placarding requirements of §172.504(a).
  • If a vehicle contains less than 454 kg (1,001 lb) of a table 2 HazMat (e.g., Division 2.2), in a non-bulk packaging, placards are not required to be displayed on the vehicle.
  • The DANGEROUS placard may be used when two or more HazMat of Table 2 in non-bulk packaging that require the display of placards are transported at the same time. The text you highlight in red states that if 1000 kg (2,205 lb) of HazMat is loaded at one facility, it must be placarded separately (per its own placarding requirements) and is not covered by the DANGEROUS placard.

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

Question2:

Daniel,

Thank you for your response. So you are saying as long as we have under 1001 lb. of 2.2 cylinders we do not have to placard? Each cylinder weighs 60lbs. If we go over that weight threshold then we would have to placard? Can you have 1001lb in a pickup and 1001lb in a trailer behind it? Or 1001lb per combination?

Thanks!

Answer2:

Please see below.

  • Correct. The placarding threshold for a Division 2.2 in a non-bulk packaging is 454 kg (1,001 lb) or more.
  • A pickup towing a trailer are subject to the USDOT/PHMSA Hazardous Materials Regulations as two separate transport vehicles. Each with its own placarding requirement. Therefore, if you had 1,000 lb of Division 2.2 in the pickup and 1,000 lb of Division 2.2 in the trailer (both in non-bulk packagings) then no placards are required on either.
  • A person operating a vehicle that does not require the display of placards does not require the HazMat endorsement on their CDL. They would require HazMat Employee Training with the additional component of Driver Training.

Contact me the next time your USDOT/PHMSA training is due to expire.

Please contact me with any other questions.

Conclusion:

 

Q&A: Can I use the Dangerous Placard for this HazMat load with Class 9 Miscellaneous?

A question through my website May 14, 2020:

Got a question about dangerous placard, today I picked up 10,000 pounds of bulk class 9 3077 1500 pounds non bulk class 3 400 pounds non bulk class 4.1 700 pounds non bulk class 8 30 pounds non bulk class 2.1 and 600 pounds non bulk 6.1 pgll at one facility so I put a bulk 9 3077 and a Dangerous on the trailer but my company said I could not cover the 1500 pounds of class 3 with the Dangerous because it was over 1001 pounds and that I should have put a bulk 9 3077 class 3 and a Dangerous. Who’s right and why?

My reply a few days later on May 20, 2020:

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

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

Info@DanielsTraining.com

https://www.danielstraining.com/

My summary of your situation:

  • All hazardous materials (HazMat) were loaded on one vehicle from one location.
  • Consignment includes the following:
    • 10,000 lb of Class 9 Miscellaneous in bulk packagings. Identification number for this HazMat is UN3077.
    • 1,500 lb Class 3 Flammable Liquid in non-bulk packagings.
    • 400 lb Division 4.1 Flammable Solid in non-bulk packagings.
    • 700 lb Class 8 Corrosive Material in non-bulk packagings.
    • 30 lb Division 2.1 Flammable Gas in non-bulk packagings.
    • 600 lb of Division 6.1 Poisonous Material (Packing Group II) in non-bulk packagings.
    • Whew!

Display of Dangerous PlacardSummary of applicable Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA):

  • Pursuant to 49 CFR 172.504(a) a vehicle transporting any amount of HazMat must display the applicable placards on the vehicle.
  • However, §172.504(c) allows for an exception from placarding if a non-bulk packaging of placarding Table 2 HazMat, and in a quantity of less than 454 kg (1,001 lb).
  • Pursuant to §172.331(c) if a bulk packaging is contained within a vehicle and the HazMat’s identification number marked on the bulk packaging is not visible, the identification number must be displayed on the vehicle.
  • When the HazMat’s identification number is required to be displayed on a vehicle, it may be displayed in any of the following methods per §172.332:
    • On orange panel.
    • On the placard.
    • On a white square-on-point.
  • Under §172.502(c), placards may be displayed on a vehicle, even when not required, if the placarding otherwise conforms to the requirements of the HMR. This is known as permissive placarding.
  • §172.504(b) allows for the display of the Dangerous placard on a vehicle as an option instead of the individual placards under the following conditions:
    • HazMat is in non-bulk packagings.
    • Vehicle contains two or more categories of HazMat that require placards specified in placarding Table 2. Note: the use of the word “require” here is misleading since, subject to permissive placarding, placards may be displayed on a vehicle even when not required. Therefore, this might better read, “vehicle contains two or more categories of HazMat where a placard type is indicated in placarding Table 2, but not necessarily required by the HMR.”
    • The Dangerous placard may not be used for a HazMat if 1,000 kg (2,205 lb) or more of that HazMat is loaded on a vehicle at one facility. Note: if 1,000 kg (2,205 lb) or more of a single HazMat is loaded on a vehicle at one facility, that portion of the load on the vehicle cannot be represented by the Dangerous placard; instead the placard specified in placarding Table 2 for that HazMat must be displayed.
  • Pursuant to §172.504(f)(9) the Class 9 Miscellaneous placard is not required to be displayed on a vehicle in the U.S. It is allowed to be displayed under permissive placarding; and, if in a bulk packaging, the identification number of the HazMat may be displayed on the placard, on an orange panel, or white square-on-point.
    UN3077 Class 9 Placard

    While not required, the Class 9 Miscellaneous placard may be displayed on a vehicle in the U.S.

  • This letter of interpretation (LOI 97-0099) is too old to be displayed on USDOT/PHMSA’s website but it indicates the quantity of a Class 9 Miscellaneous is not required to be included when determining the applicability of the placarding exception threshold (454 kg or 1,001 lb). Note: However, under permissive placarding, the quantity of Class 9 Miscellaneous may be included when determining the option to display the Dangerous placard. The HMR is unclear on this point. I submitted a request for a letter of interpretation from USDOT/PHMSA in June of 2020 and will post a link once received.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

My answer:

  • You are correct.
  • Since the Class 9 Miscellaneous is in a bulk packaging, it cannot be covered by the Dangerous placard.
  • While the display of the Class 9 Miscellaneous placard is not required within the U.S. it may be displayed subject to permissive placarding. Also, since the Class 9 Miscellaneous is in a bulk packaging it’s identification number (3077) must be displayed on the vehicle. It’s display on the placard is one allowed option.
  • Since all of the remaining HazMat loaded at the facility are non-bulk packagings, found in placarding Table 2, and not more than 1,000 kg (2,205 lb), the Dangerous placard may be used to account for the remaining HazMat.

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

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Q&A: I have two or more HazMat on a Vehicle. Can I use the Dangerous placard?

A common question for anyone who transports hazardous materials by highway is some variation of, “When, and how, do I use the Dangerous placard”? I received another of these questions from someone in the transportation industry on June 27, 2016:

If I have over 1,001 lbs but less than 2,205 lbs of a hazard class plus under 1,001 of another hazard class can I use a dangerous placard? All hazard classes are in table 2.Dangerous Placard

I had a response ready for him (6.27.16):

Thank you for contacting me with your question.  I believe I have an answer for you.

  • When a vehicle contains 1,001 pound of more of hazardous materials in non-bulk packages, it must display the applicable placard for each hazardous material [49 CFR 172.504(a)].  Unless an exception exists.
  • A vehicle that contains 2 or more hazardous materials in non-bulk packages that require placards may substitute the Dangerous placard for the placards representing each hazard  [49 CFR 172.504(b)].
  • The Dangerous placard option is not available for certain HazMat identified in Table 2 at 49 CFR 172.504(e)  [49 CFR 172.504(b)].
  • However, when 1,000 kg (2,205 lbs) or more of one category of material is loaded at one facility, the placard for that HazMat must be displayed on the vehicle  [49 CFR 172.504(b)].  Read:  When not to use the Dangerous Placard.

I hope this helps.

Please don’t hesitate to contact me with any other questions.
He wanted a little clarification so he re-phrased the question:
To better phrase my question, if I had say 1,400 lbs of class 8 Corrosive and 300 lbs of 2.2  Non-Flammable Gas could I use a Dangerous placard to cover both or could I just use a Corrosive placard to cover the class 8 only due to the class 2.2 being less than 1,001 lbs?  What if the class 8 was 800 lbs and the class 2.2 was 350 lbs for a total of 1,150 lbs?  How would I need to placard that, if at all?
Thanks,
My reply:

I will answer your questions separately:

  • Scenario 1:  1,400 lbs of class 8 Corrosive and 300 lbs of 2.2  Non-Flammable Gas.  In this scenario the aggregate weight of HazMat in Table 2 of 49 CFR 173.504(e) on the vehicle is ≥1,001 lbs which, per 49 CFR 173.504(a) and (c) requires the vehicle to display placards for both Class 8 and Class 2.2.  USDOT regulations at 49 CFR 173.504(b) allow for the option to display the Dangerous placard in situations where two or more HazMat on a vehicle are required to display placards.  That is the situation here.  Therefore:
    • Option 1 – Vehicle displays Class 8 Corrosive and Class 2.2 Non-Flammable Gas placards.
    • Option 2 – Vehicle displays Dangerous placard only.
  • Scenario 2:  Class 8 was 800 lbs and the class 2.2 was 350 lbs for a total of 1,150 lbs.  See Scenario 1.
  • Scenario 3 (mine):  Class 8 Corrosive 500 lbs.  Class 2.2 Non-Flammable Gas 300 lbs.  In this scenario the aggregate gross weight of the HazMat in Table 2 of 49 CFR 173.504(e) on the vehicle is <1,001 lbs.  Therefore, per 49 CFR 173.504(c) placards are not required to be displayed on the vehicle.  USDOT regulations at 49 CFR 173.502(c) allow for the display of placards when not required if the HazMat is present.  However, the Dangerous placard may only be displayed if required.  Therefore:
    • Option 1 – Vehicle displays no placards.
    • Option 2 – Vehicle displays Class 8 Corrosive and Class 2.2 Non-Flammable Gas placards.
I think that satisfied him.

The use of the Dangerous placard is a source of confusion for many in the transportation industry.  It’s certainly not the first question I’ve received.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Q&A: Using the Dangerous Placard in Place of Multiple HazMat Placards

A question posted to a Yahoo! Group back in November 2015:

Comparing notes.

For shipments in the U.S.
For shipments of hazardous materials that require placards of truck load of non-bulk packages, you are allowed to use the Dangerous placard in place of multiple hazard class placards (under certain conditions).

Can you you use the Dangerous placard if the load is only one Hazrad Class?

Same question for Canada for the Danger placard?

Thanks in advance.

Someone gave a reply before I did the next day:

49CFR 172.504 (b) DANGEROUS placard: …….”non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of this section may be placarded with a DANGEROUS placard instead of the separate placarding specified for each material…..”

So, it has to be 2 different hazards.  Also, can’t be used to substitute placarding from Table 1, and can’t be used if 1,000 kg (2205#’s) or more of ONE hazard class is loaded at one facility.

Here’s my reply just a few hours earlier:

I cannot speak with certainty about the Canada regulations, but I know that in the U.S. PHMSA/USDOT does not allow the use of the Dangerous Placard if there is only one HazMat on the vehicle.

Please see point #3 in this article:  When not to use the Dangerous placard.
I suspect that TDG Canada regulations are the same.
I hope I contributed something valuable to the conversation.

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Q&A: Displaying the DANGEROUS Placard on a Motor Vehicle

Question from previously unknown contact on April 2, 2015 through the Contact Me page of my website:
Hazard Class 3 Flammable Liquid Placard

Placard on Cargo Tank Motor Vehicle for UN1866 Resin Solutions

Good morning, to my understanding I’ve known that we need placards on flammable over 1000 lb.  But when we have 324lb. of 4.1 Flammable and 525 lb. of UN1866, resin solution.  Is it ok to use Dangerous only or both placards? Tks!

My reply later that same day:
Dangerous Placard

The Dangerous Placard can be used in a variety of situations – with limitations – when transporting HazMat

Thank you for contacting me.  I will try to answer your question below:

  • You are correct that vehicles transporting quantities of most HazMat, including Class 3 Flammable Liquids, of ≥1,001 lbs must display HazMat Placards on all four sides of the vehicle.
  • The amount of HazMat you describe is not enough to require placards to be displayed on the vehicle (324 lbs + 525 lbs = 849 lbs).  Though the driver may display placards in this instance if he wishes to.  Please read this article:  Driver Option to Display Placards When not Required.
  • If displaying placards at the driver’s discretion or if there is enough HazMat to require placarding the vehicle (e.g. 501 lbs of Division 4.1 Flammable Solid and 500 lbs of Class 3 Flammable Liquid) the driver has two options:  1.  Display the distinct placards for the separate HazMat (4.1 Flammable Solid & 3 Flammable Liquid) or; 2.  Display the Dangerous placard alone.  Please read this article:  Use of the Dangerous Placard for Shipments of HazMat.
Hazard Class 3 Flammable Liquid Placard

The display of the Class 3 Flammable Liquid placard is required for certain shipments of HazMat

Also, for general information about acceptable display of placards, please see this article:  What’s Wrong With These Pictures? Incorrect Display of Placards.

I hope this helps.
Please don’t hesitate to contact me with any other questions or if you require HazMat Employee Training (including Driver Training).
Dan
Another satisfied HazMat Shipper(April 2, 2015):
Thank you very much Daniel..
Please let me know if you have any questions about the transportation of hazardous materials; I’m here to help.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

When not to use the Dangerous Placard for Shipments of HazMat

Unless an exception exists, each bulk packaging, freight container, unit load device, transport vehicle or rail car (see 49 CFR 171.8 – Definitions for a better understanding of these terms) containing any quantity of a hazardous material must be placarded on each side and each end with the type of placards specified in tables 1 and 2 found at 49 CFR 172.504(e).  The DANGEROUS placard is a useful tool for carriers of hazardous materials because it allows them to substitute one placard for any two or more hazardous materials that require placarding. (more…)