From the contact form on my website on December 9, 2016:

We have a trailer with two Deck Engines w/ a 400 Gal. Diesel Tank that supply’s Fuel to both engines.

Question 1. Do we have to Placard the on all for sides of the tank.

2. Does the driver need a Haz-mat Endorsement. Thanks.

(the email included a picture of a flat bed trailer hauling the deck engine and two intermediate bulk containers of diesel fuel.)

My reply December 11th:

Please see below:

• Diesel fuel is classified as a Class 3 Combustible Liquid.
• The diesel tanks on the trailer classify as a bulk packaging. The packaging is known as an IBC or Intermediate Bulk Container.
• A bulk packaging of a combustible liquid is not subject to the exception at 49 CFR 173.150(f).
• The requirements to use DOT specification packaging is not applicable to a bulk packaging of a Class 3 Combustible Liquid.
• The placarding requirements of 49 CFR 172, subpart F do apply to this HazMat.
• Per 49 CFR 172.514(c)(4) an IBC is required to display the applicable placards on two opposing sides. The 4-digit identification number must appear on or near the placard. Alternatively, the IBC may display HazMat labels and the proper shipping name and identification number on only one side.  Read:  HazMat Labels, Placards, and Marks on an IBC.
• Per 49 CFR 172.504(a) each transport vehicle required to display placards (as in this situation) must display them on all four sides of the vehicle.
• 49 CFR 172.516(a) requires the placards to be visible from the direction they face.
• The placards on the IBCs may suffice to replace the required placards on the side of the truck that the placarded IBCs face. In short, if placards are displayed on the IBCs so that they are visible from all four sides of the vehicle, you can meet both requirements with the same 4 placards. A more conservative approach is the display placards or HazMat labels on the IBCs as required and also display placards on all four sides of the vehicle.

I hope this helps.

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

I guess that did it because I didn’t hear back from him.

Please feel free to contact me if you have any questions about the transportation of a combustible liquid.  See below for links to other articles for more information.

• Can I re-class a Flammable Liquid to a Combustible Liquid?
• The White Bottom Placard for a Class 3 Combustible Liquid
• Use of Flash Point for Classification of Class 3 Flammable and Combustible Liquid
• Flammable Liquid v. Combustible Liquid
• The Combustible Liquid Exception

Question to the Contact Me page of my website on March 7, 2015:

Looking for guidance on the shippers responsibilities in reference to DOT hazmat regs when shipping empty 6,000 fuel tank trailers. The tank trailers have been re-built, pump tested, drained (but not triple rinsed), contain residual diesel fuel (50 gal or less) and will be loaded on another conveyance/trailer for transport (will not be towed).

My “Thanks and give me some time” response on March 9th:

That’s a good question. Let me do a little research and get back to you sometime later this week.

Questioner’s acknowledgement and a little more information (3.9.15):

Thank you Daniel.

We are being told the trailers must have a drain and purge certificate (be purged and triple rinsed) and hazmat certification documents prepared prior to shipment; however purging with water causes problems with the functionality of the tanker if it sets in storage for a while before shipment. The trailers are drained but there is residual diesel remaining in the pump filters, etc.

The Big Answer on March 13th:

What you describe (a 6,000 gal fuel tank trailer) is identified in the Hazardous Material Regulations (HMR) of PHMSA/USDOT as a Cargo Tank.  From 49 CFR 171.8:

Cargo tank means a bulk packaging that:
(1) Is a tank intended primarily for the carriage of liquids or gases and includes appurtenances, reinforcements, fittings, and closures (for the definition of a tank, see 49 CFR 178.320, 178.337-1, or 178.338-1, as applicable);
(2) Is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment to a motor vehicle is loaded or unloaded without being removed from the motor vehicle; and
(3) Is not fabricated under a specification for cylinders, intermediate bulk containers, multi-unit tank car tanks, portable tanks, or tank cars.

When a Cargo Tank is part of a motor vehicle it is identified as a Cargo Tank Motor Vehicle.  Also from 49 CFR 171.8:

 Cargo tank motor vehicle means a motor vehicle with one or more cargo tanks permanently attached to or forming an integral part of the motor vehicle.

So, what you describe is the transportation of a Cargo Tank that contains the residue of a hazardous material (I assume the diesel fuel is a Class 3 Flammable or Combustible Liquid).  The HMR regulates a packaging containing any residue of a hazardous material the same as if it was full.  There is an exception from some of the requirements of the HMR available to packaging with HazMat residue, but it does not apply to a bulk packaging as in this situation.

Learn more about the transportation of packaging with HazMat residue

Available options:

• Transport the HazMat residue-containing Cargo Tanks as hazardous materials subject to all of the requirements of the HMR.  This includes shipping papers, placards, HazMat labels, markings, HazMat Employee training, registration as a Shipper of HazMat, providing emergency information, &etc.
• Remove all residue from the Cargo Tanks so that they are rinsed, cleaned, and purged of all vapors.  Then ship as non-hazardous.
• Fill the Cargo Tanks with some non-hazardous material that is compatible with the residual diesel fuel so that the resulting mixture is non-hazardous.

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

Dan

815.821.1550

Another grateful HazMat Shipper (though not yet a customer) on March 13th:

Daniel,Thank you so much for taking the time to research this issue and I really appreciate the guidance and options you provided.

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://danielstraining.com/

I receive and respond to questions like this all the time.  Let me help you with the questions you have about the transportation of hazardous materials.