identification number

Q&A: What hazard communication (marks, labels, & placards) are required on a bulk packaging and a vehicle transporting a bulk packaging?

Q&A: What hazard communication (marks, labels, & placards) are required on a bulk packaging and a vehicle transporting a bulk packaging?

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:

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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!

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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.

Q&A: Does a bulk packaging require the display of the HazMat’s identification number on the vehicle?

Q&A: Does a bulk packaging require the display of the HazMat’s identification number on the vehicle?

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

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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.)

Hazardous materials placard with identification number

 

    • On an orange panel near the placard.

 

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

NA1993 Mark with Plcard

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.

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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.

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

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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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!

Q&A: Is it legal to hand write the UN numbers on a placard with a magic marker?

Q&A: Is it legal to hand write the UN numbers on a placard with a magic marker?

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.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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

Q&A: Are Forty 55-gallon drums on one truck considered to be bulk?

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:UN1824 on Class 8 Placard

No it is not.

Please see below for an explanation:

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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?

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My reply the next day:

I will attempt to answer your questions below.

  • Scenario 1:  “What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?”
    • Answer:  In this scenario you must display the applicable placards for each HazMat unless one of the placarding exceptions at 49 CFR 172.504(f) apply.  If both HazMat are in a non-bulk packaging you must not display the identification number.  If either of the HazMat are in a bulk packaging you must display its identification number on or near the placard.
  • Scenario 2:  “Same scenario but you picked them up from two separate shippers?”
    • In this scenario the vehicle would display the applicable placard and identification number for the first shipment (assuming all of the other conditions of 49 CFR 172.301(a)(3) are met).  When the second shipment is picked up the placard for the second HazMat must be displayed, but not its identification number.  The identification number and placard from the first shipment would continue to be displayed (this is based on a conversation with the HazMat InfoLine. It is not clear from the regulations. I could not find a letter of interpretation to confirm).
  • Scenario 3:   “Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?”
    • If both HazMat picked up from one shipper then Scenario 1 from above will apply.
    • If picked up from two separate shippers then Scenario 2 will apply.

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

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.

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That seemed to answer all of his/her questions.

I frequently receive questions about placarding vehicles.  As you can see from this Q&A, there are many scenarios to consider and each may require a different display of placards.  If you are a carrier of HazMat, make certain you display the correct placards.  If you are a shipper of HazMat (i.e., you offer the HazMat to a carrier for transport), make certain you offer the correct placards to the driver.

As a shipper or a carrier, make certain all of your employees with a direct affect on the safe transport of HazMat receive initial and triennial HazMat Employee training.

Q&A: When must I – and when can’t I – display the identification number on a placard?

Q&A: When must I – and when can’t I – display the identification number on a placard?

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?

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My reply the next day:

Thank you for contacting me.  Please see below.

I hope this helps.

Please contact me with any other questions.

It took awhile, but on May 23rd he still had questions:
Class 8 placards with ID number

There are at least four separate bulk packagings on this vehicle.

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.

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                    Info@DanielsTraining.com

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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).

Q&A: When transporting IBCs, must the identification number be displayed on the vehicle?

Q&A: When transporting IBCs, must the identification number be displayed on the vehicle?

Question (March 03, 2018):

Sir, my company routinely ships HazMat totes 275-over 300 gallons that have UN numbered placards on two sides on freight trailers that are placarded that don’t have the UN number, like the kind used for packaged HazMat.

But,,,I remember from HazMat class at previous jobs that if there’s a UN number on the tote, it’s a bulk container and needs bulk placards with that UN number on all four sides of the truck.

Is this correct..?,, because this is the case often in freight companies, even the supervisors don’t know.
They say that no where does it say it’s illegal to use standard placards for bulk container transportation.

Note: An image of an intermediate bulk container (IBC) was included as an attachment to the email.  A Class 3 Flammable Liquid placard with the identification number of (UN)1170 was visible on one side.

My reply (March 05, 2018):

Thank you for contacting me.  Please see below.

  • The packaging you describe and the image shown is an intermediate bulk container (IBC).
  • The Hazardous Materials Regulations allow for many options for the display of labels, placards, and package marks on an IBC of this size.  Read:  HazMat Labels, Placards, and Marks on an IBC.  However, in one form or another the identification number must be displayed on the IBC.
  • Per 49 CFR 172.331(c) when a bulk packaging like an IBC is contained in or on a transport vehicle the identification number marking on the IBC must be visible or the transport vehicle must be marked with the identification number on each side and each end.
  • Per 49 CFR 172.332, the identification number mark on a transport vehicle may be displayed in one of three ways:
    1. On the placard (172.332(c)).
    2. On an orange panel near the placard (172.332(b)).
    3. On a white square-on-point near the placard (172.336(b)).

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

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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His reply the next day (speaking some truth):

Daniel,,,,,,,, Thank You very much for the info. I forwarded this to my terminal manager.

You would be surprised to know how many freight drivers (City and shuttle drivers) do not follow the hazMat regs.

I have worked in fuel and oil jobs in the past. But in many cases Freight Companies hire drivers with zero HazMat experience and the company does not provide any HazMat training.

Well, maybe on paper, but not in actuality.

Conclusion:

Beware the things that “everyone knows to be true” about the Hazardous Materials Regulations (HMR) of USDOT/PHMSA.  Sometimes what everybody knows turns out to be wrong.  The correct answer can only be found in the HMR.  You – or your employees – may contact me directly to get the answers to these questions or you could get your questions answered and fulfill the training requirements of the HMR by attending my HazMat Employee training.

Q&A: Do I have to provide the placard with the identification number on it?

A question from someone who had recently attended my Onsite Training (01.18.18):

I just had your DOT training this month, and I ask which placards to use when shipping our product(with a UN 3190 self heating solid). I am still having problems with drivers as to which placards to use.

Yesterday I shipped 123 drums of product each drum contains 200 lbs. This was shipped on 31 skids as a truck load at 24,600 lbs.

This is the problem:

It is my understanding that when I ship this product as a truck load I would use the placard (Spontaneously Combustible 4 )When the driver call the load in to his safety department they requested we use the placard (Spontaneously Combustible 4 with the UN 3190) on it. They would not take the load with out it. Because the amount was over 8,820 lbs it had to have the UN# on it.

So I gave the driver both types of placards. Is this right to do or not? Which placard is right to use in this case.

Thanks for any help you can give.

My reply the same day:

Good question.  Please see below.

Placards:

  • The placard for a Division 4.2 Spontaneously Combustible is required if the total amount of all hazmat on the vehicle is equal to or greater than 454 kg (1,001 lb).
  • The placard must meet the specifications for shape, design, &etc.
  • Placard must be displayed on all four sides of the vehicle.

Identification number mark:

  • Per 49 CFR 172.301(a)(3) a transport vehicle must display the identification number for a hazmat under the following conditions:
    • Non-bulk packaging (e.g., 55-gallon drum).
    • Vehicle contains only a single hazmat.
    • Each package is marked with the same proper shipping name and ID #.
    • Total weight of hazmat is equal to or greater than 4,000 kg (8,820 lb).
    • All hazmat loaded at one loading facility.
    • Transport vehicle contains no other material (hazmat or non-hazmat).
  • Identification number must be displayed on all four sides of vehicle.
  • Identification number may be displayed on placard or near placard on orange panel or white square-on-point.

Answer:  Vehicle must display placard for Division 4.2 with identification number (3190) on or near placard.  It is not necessary to provide both.

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

Q&A: Display of Identification Number on Bulk Packagings in Transportation

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Here is a type of question I receive frequently (5.11.16):

Good Morning.
I’m pulling a gooseneck trailer which is carrying two one- way totes of 1760 (corrosive solution) and 1 tote of 1824 (50% caustic). Both totes have proper labels and Id’s on opposite ends. Can I placard the trailer using only (8) corrosive placards or do I need 2 sets of placards with proper id’s?

UN3266 in Intermediate Bulk Container (IBC)My reply that day:

That is a good question. I will try to answer it here, if you need more information I can provide that later.

You are required to display the identification number for each bulk packaging of a different HazMat that you have on your vehicle. In this case you have two different identification numbers. You must display both on all four sides of the vehicle.

However, if the identification numbers are visible on the totes while in transportation on all four sides of the vehicle, then it is not necessary to display the identification number with the placards on the vehicle.

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

He must have been waiting for an answer because within a few moments I received this reply with further questions:

Daniel,

First of all allow me to thank you for your prompt response.
Second, did i read correctly  that a newsletter was available for purchase?
Third, I’m very aware of the difficulty of answering a DOT hazmat load question where there is no gray area.
So with that in mind, I have loaded 1 bulk package with ID’s on all four side thus not having to placard the vehicle.
But with 3 totes, 2 with 1760 and 1 with 1824,  and only 2 id’s on opposite ends of each tote would that still allow me to use only 8 Corrosive placards?
I know…wow.
My reply that same day:

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You can display the solely the Class 8 placard on all four sides of the vehicle as long as both of the two distinct identification numbers (1760 & 1824) are visible on all four sides.
If the identification numbers are not visible on all four sides of the vehicle, then it is necessary to display them on the vehicle.  This can be done in one of three ways:
  • On the placard.  One ID # per placard.
  • On an orange panel near the placard.  One ID # per orange panel but only one placard.Intermediate Bulk Container of UN3082
  • On a white square-on-point near the placard.  One ID # per white  square-on-point but only one placard.
In short, both of the two ID #s and at least one placard for the hazard class must be visible on all four sides of the vehicle.  How you do it is up to you.
I hope this helps.  Please contact me with any other questions.
That must have done it because on May 12, 2016 I received the final message:
Thank you.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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Q&A: Markings on a Bulk Packaging (Roll-off)

Another question through the Contact Me page of my website on April 3, 2016:

Dear Daniel,
A bulk container (rolloff box) requires to display the UN number in the sides?
Best Regards

My reply the next day (4.4.16):

Yes.  Pursuant to 49 CFR 172.302(a), a bulk packaging must display the identification number on all four sides if it has a capacity of 1,000 gallons or more and on two opposing sides if it has a capacity of less than 1,000 gallons.

Pursuant to 49 CFR 172.302(b), markings on a roll-off must have a width of at least 0.24 inch and a height of at least 2 inches.
I hope this helps.
Please don’t hesitate to contact me with any other questions.
Here’s some more information on this topic:

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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The Identification Number Marking on Transport Vehicles and Freight Containers

When required on transport vehicles or freight containers (defined below), identification numbers for hazardous materials (found in Column 4 of the Hazardous Materials Table) must be displayed in one of three ways as detailed in 49 CFR 172.336.  The allowable methods for display of identification numbers are as follows:

  • On orange panels with the specifications as detailed in §172.332(b),
  • On a plain white square-on-point display configuration that has the same outside dimensions as a placard:  250 mm (9.84 inches) on a side, or;
  • On a placard in conformance with the requirements of §172.332(c).

If a situation arises where both placards and the identification number are required but the display of the identification on the placard is prohibited per §172.334(a), then the identification number must be displayed on an orange panel or the plain white square-on-point display configuration.  Both must be displayed in association (i.e. next to) the required placard.

Definitions used in this article:

Transport vehicle means a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, rail car, etc.) is a separate transport vehicle.

Freight container means a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.

So, a question:  Is the display of the identification number in this photo in compliance with the Hazardous Material Regulations (HMR) of the PHMSA/USDOT?
Identification number for a Class 9 liquid

Is this display in compliance with 49 CFR 172.336(b)?

The answer is yes.  The identification number seen in the photo (3082) applies to a Hazard Class 9 liquid.  Not having seen inside the truck, I will assume that it contains a bulk packaging (>119 gallons for a liquid) of a Class 9.  The transportation of a Class 9 in a bulk package inside a transport vehicle mandates the display of the identification number on all four sides of the vehicle.  The HMR do not, however, require the use of the Class 9 placard for domestic transportation (read my article to learn why a Class 9 placard is not required for domestic transportation).  In this case the carrier has opted to display the identification number on his vehicle without the Class 9 placard.

Something like this may catch your eye on the highway (it did mine, anyway) and cause you to wonder how it can be so.  A review of the regulations reveals the reason why.  Take the time to attend one of my Training Webinars and you’ll learn about the HazMat transportation regulations of the PHMSA/USDOT.