Each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device must—
(2) Be located clear of appurtenances and devices such as ladders, pipes, doors, and tarpaulins;
Placards must be located clear of appurtenances and devices on the vehicle.
Notice how the placard holders on this vehicle are placed higher in order to ensure they are visible when the lift gate – an “appurtenance” or “device” if I ever saw one – is stowed in place for transportation.
Can the placards be too high on the side or end of the vehicle? Or, too low? No, at least not as far as the Hazardous Material Regulations of the PHMSA/USDOT are concerned. There is no mention in the HMR of the specific placement of HazMat placards on the vehicle as long as they appear on all four sides, “…on each side and each end…” pursuant to §172.504 and meet the further requirements of §172.516, one of which we see here. Other requirements of §172.516(c) include:
Placard must be securely attached to the vehicle or placed in a holder (as is the case in photo).
So far as practicable, placard must be located so that dirt or water is not directed to it from the wheels of the transport vehicle.
At a minimum the placard must be located at least 3 inches (76.0 mm.) away from any marking (such as advertising) that could make it harder to see.
Text printed on the placard must be displayed horizontally, reading from left to right.
Placard must be maintained by the carrier in good condition so that it doesn’t become unreadable due to dirt, damage, wear, &etc.
Placard must be affixed to a background of contrasting color, or must have a dotted or solid line outer border which contrasts with the background color.
Contact me if you’re uncertain of how to display HazMat placards on any bulk packaging, freight container, unit load device, transport vehicle or rail car.
The determination of the placarding requirements for a shipment of hazardous materials (found at 49 CFR 172, Subpart F) are, initially, straightforward. Placarding of a transport vehicle or freight container to be transported by highway or rail is required for…
Any quantity of a hazardous material found in Table 1 of the Placarding Tables.
Any quantity of a hazardous material found in Table 2 of the Placarding Tables in a bulk packaging.
When the aggregate gross weight of all Table 2 hazardous materials in non-bulk packagings in the transport vehicle or freight container is ≥1,001 lbs.
But of course, it gets more complicated from there. You may be surprised to learn that 49 CFR 172.502(c) allows for the display of placards for a hazardous material even when not required by regulation, if the placarding otherwise conforms to the requirements of 49 CFR 172, Subpart F.
So, this means that even if none of the conditions in #’s 1-3 above are met, a carrier may desire to display placards on a shipment of hazardous materials and this will not be in violation of the Hazardous Materials Regulations (HMR).
The HMR are filled with little exceptions and restrictions just like this one. Make certain you and your HazMat Employees have received the training required by 49 CFR 172, Subpart H to ensure they maintain your company’s regulatory compliance. Contact me for a free consultation on your training needs.
In an earlier article I wrote about the requirement of the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) to ensure the visibility of placards on a motor vehicle or rail car in transportation. Read: Visibility Requirements for Hazardous Materials Placards.
Those regulations at 49 CFR 172.516(a,b) affect where a carrier must display HazMat placards on a rail car or motor vehicle. Also important – and the subject of this article – are the remaining requirements of that part – §172.516(c-e) – for the display of hazmat placards in all vehicles and all packagings that require placards. (more…)
