Question1:

If I have a single 55 gallon drum that weighs over 882 is it considered a bulk… Hold it right there!

Answer1:

In an earlier article I addressed the false premise contained in that first question and explained that the packaging described (55-gallon drum) is not a bulk packaging and is violation of the HMR if it has a maximum net mass of more than 882 lbs; I suggest you read that article first (Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?). In this article I’ll answer the remaining questions poased as if it is a bulk packaging (it isn’t).

Question2:

“…and would it require a un number…”?

Answer2:

“…and would it require a un number”?

• Yes. The HazMat’s identification number must be marked on both a bulk and non-bulk packaging.
• There are several options for the display of the identification number on a bulk packaging:
  • A bulk packaging with a capacity of 3,785 L (1,000 gal) or more must display the identification number on all four sides.
  • A bulk packaging with a capacity of less than 3,785 L (1,000 gal) may display the identificatin number on only two opposing sides.
  • There are several options for the display of hazard communication on an intermediate bulk container (IBC).

Question3:

“next question if I have a bulk container that requires a un number but I also have non bulk waste under the same un number do I have to placard my trailer with both the un number and a class placard or will the un number cover both.”?

Answer3:

• Both the placard and identification number must be displayed on the vehicle.
• If the identification number displayed on a bulk packaging is not visible in transportation, e.g., it is inside a cargo trailer, then it is necessary to display the identification number on all four sides of the vehicle.
• A bulk packaging containing any amount of any HazMat requires the vehicle to display the applicable placard for the HazMat on all four sides of the vehicle.
• In this case the vehicle must display the identification number and the applicable placard for the HazMat in the bulk packaging. This can be displayed in one of three ways:
  • The identification number may be displayed on the placard.
  • The identification number may be displayed near the placard on an orange panel.
  • The identification number may be displayed near the placard on a white square-on-point.

• If an identification number is displayed on a vehicle it must represent all of the HazMat of that Class in the vehicle. Since you indicate you have a bulk and non-bulk packaging of the same identification number, a placard representing the Class and the identification number must be displayed on all four sides of the vehicle. Read: When not to Display and ID# on a Vehicle

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

Conclusion:

A tough question because the inquisitor started with an incorrect understanding that its OK for a 55-gallon drum to weigh more than 882 lb – it’s not!

Sometimes knowing the right question to ask requires a basic understanding of the USDOT/PHMSA Hazardous Materials Regulations. My monthly HazMat Employee Training Webinars can do just that.

A question from a shipper or carrier of HazMat (07.31.20):

I am hauling NA 1993 combustible liquid pg3 (2-methyoxymethylethoxy propanol) in a tote of 350 gallons. Its total weight is 2329lbs. This is the only hazmat on the truck.

*bulk haz. Mat placard accordingly*

Do I need to put UN number on the truck? Could you help me when is to put un number onto placards? Your help would really be appreciated.

Thanks

My reply that same day:

I will try to answer your question below.

• You indicate your HazMat is a Class 3 Combustible Liquid.
• I understand the HazMat is contained and transported in a bulk packaging (i.e., has a capacity of more than 119 gallons).
• More specifically, the packaging is a tote, which I presume to be an intermediate bulk container (IBC).
• The HazMat Regulations for the display of labels, marks, and placards on an IBC are complex. Read: HazMat Labels, Markings, and Placards on an Intermediate Bulk Container
• A vehicle transporting a bulk packaging of a HazMat must display both of the following on all four sides of the vehicle or freight container:
  • The placard (in this case the Class 3 Combustible Liquid).
  • The identification number (in this case NA1993). It is displayed solely as “1993” it is not necessary to include the “NA”.
• The identification number can be displayed in any one of three ways:
  • On the placard. (The white in the bottom of the placard is an option and is not required.)

• • On an orange panel near the placard.

• • On a white square-on-point near the placard.

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

He wanted some more information:

Thank you for the information. Could you please tell me more when to include UN number. I always have same issue number of times.

Thanks in advance.

I had the information:

Sure:

Any time you have a hazardous material in a bulk packaging (>119 gallons), the identification number must be displayed on all four sides of the vehicle.

• This is true if the vehicle itself is a bulk packaging, such as a cargo tank or portable tank.
• Or, if the bulk packaging – such as an intermediate bulk container (IBC) – is loaded on a vehicle. Unless the identification number displayed on the bulk packaging is visible while in transportation. Read: Q&A: When transporting IBCs, must the identification number be displayed on the vehicle?

Also, the identification number must be displayed on a vehicle if it contains a large amount of a single HazMat in a non-bulk packaging. Read: Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings

That seemed to do it!

Thanks a lot.

Conclusion:

The Hazardous Materials Regulations of USDOT/PHMSA are a challenge for both shippers and carriers of HazMat. If you have a question, contact me. If you need HazMat Employee training, contact me!

Another one of the questions I get. This one in December of 2020:

Is it legal to hand write the UN numbers on a black UN placard with a magic marker ?

My reply:

Yes. Maybe.

Per 49 CFR 172.338, if more than one of the identification number markings displayed on placards, orange panels, or white square-on-points is lost, damaged, or destroyed during transportation, the carrier shall replace all missing or damaged identification numbers as soon as practicable.

In such case the numbers may be entered by hand using an indelible marking material as long as it is legible.

So, it can only be done by the carrier (i.e., driver) and can only be done during transportation, i.e., while on the road.

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

Just a quick question June 19, 2018:

Is carrying 40 – 55 gallon drum of NaOH on a box trailer considered bulk?

Sent from my iPhone

My reply just an hour later:

No it is not.

Please see below for an explanation:

• A bulk packaging is one with a capacity of greater than 119 gallons. Read: Bulk Packaging for HazMat Explained!
• Your containers are 55 gallons each.
• The total volume of the shipment is not a factor.
• You may, however, need to display the identification number for the hazardous material on the vehicle.
  • Read:  Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings
  • Read: Display of the Identification Number on Transport Vehicles and Freight Containers

Her gracious reply:

Thank you. That’s what I thought but just wanted to make sure.

I wasn’t done (I have so much to share!):

You’re welcome!

You may wish to read this article I wrote indicating when it is necessary to display the identification number on a transport vehicle if it contains a large quantity of a single HazMat:  Vehicle Marking Requirements for Single HazMat.

That spurred another question (06.20.18):

I read the other article you sent and it did clear up when to use numbered placards on a straight forward shipment. Other scenarios would also be helpful.

• What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?
• Same scenario but you picked them up from two separate shippers?
• Another:  Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?

My reply the next day:

I will attempt to answer your questions below.

Date: May 10, 2018

Subject: Corrosive example for placarding on the website

Message Body:

UN 3264, Waste Corrosive Liquid, Acidic, Inorganic, n.o.s  (Hydrochloric Acid, Hydrogen Peroxide), 8, II – 6 x 55 gallon drums @ 600 lb/drum = 3,600 lbs
UN1760, Waste Corrosive Liquid, n.o.s. (Nitric Acid, Hydrofluoric Acid), 8, II – 1 x 350 gallon bulk packaging = 350 lbs

So two corrosive 8 placards with both UN numbers is required in this example. What would be required if there were no bulk items?

My reply the next day:

Thank you for contacting me.  Please see below.

• Two separate Class 8 Corrosive placards must be displayed on all four sides of the vehicle.
• The identification number 3264 is not required to be displayed on a Class 8 placard since the HazMat is not in a bulk packaging and it is not the sole HazMat in the vehicle.
  • Read: What is a bulk packaging?
  • Read: Display of Identification Number on Vehicle Carrying Large Quantity of Single HazMat in non-bulk packaging
  • Read: When not to Display the Identification Number on a Vehicle
• The identification number 1760 is required on a Class 8 placard since the HazMat is in a bulk packaging.
• If no bulk items then one Class 8 Corrosive placard per side with no identification number would suffice.

I hope this helps.

Please contact me with any other questions.

It took awhile, but on May 23rd he still had questions:

Thanks for the answer but I’m still confused. (when must an identification number not be included on a hazardous material placard) it says “the solution is to display each applicable identification number in one of the following manners”. “on separate placards of the same hazard class”. In your response you say the identification number isn’t “required” for 3264. Wouldn’t it be prohibited to put the 3264 number on the placard since it is not bulk and does not cover the entire load? Can I use a placard with the 3264 and one with 1760 or MUST I use a plain corrosive 8 placard with a 1760 placard?

I tried to clarify:

I will try to clarify.

• Vehicle must display two Class 8 Corrosive placards on all four sides.
• One of the placards on each side must display the identification number 1760. It represents the Class 8 Corrosive in a bulk packaging.
• The other Class 8 placard must not display an identification number. It’s purpose is to represent the non-bulk quantity of Class 8 Corrosive (UN2364).

Please contact me if you have any other questions.

Daniels Training Services, Inc. 815.821.1550                     Info@DanielsTraining.com https://danielstraining.com/

That must have done it.

The requirements for display of placards on a vehicle can be complicated.  Having to also display the HazMat’s identification number on or near the placard can complicate things further.  Whether you transport a HazMat (carrier) or offer for transport (shipper) you must determine what placards and/or identification numbers are required to be displayed on the vehicle and then either offer them to the driver (responsibility of the shipper) or display them properly on the vehicle (responsibility of the carrier).