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markings

Specification packaging marking on IBC

Specification Packaging Markings on Intermediate Bulk Containers of Hazardous Materials

Like all packagings used for the transportation in commerce of a hazardous material an Intermediate Bulk Container (IBC) must be authorized for the HazMat it is intended to contain. It must also, unless an exception is used, be designed, manufactured, and tested to meet a specification in the form of the UN standards (UN for United Nations) and be marked to demonstrate this.

Note:  Specification packaging for an IBC – like all other non-bulk packagings but unlike most bulk packagings – means the UN standard and not the DOT specification.

In an earlier article I identified and explained the general requirements for all specification packaging markings at 49 CFR 178.3.  This article will expand on those general requirements and look just at those that apply to an Intermediate Bulk Container at §178.703. (more…)

What’s on that Truck? The Identification of Hazardous Materials in Transportation

Hazardous materials are a common fixture in our modern lives and an essential ingredient in many of things we take for granted; like drinking carbonated soda from the fountain at our favorite restaurants.  Well, the HazMat has to get to the restaurant somehow and that’s where its transportation in commerce becomes necessary.  Now, we all want the transportation of hazardous materials on our highways and in our neighborhoods to be safe, so that’s why we have the Hazardous Material Regulations of the PHMSA/USDOT.  One way the HMR ensures the safe transportation of hazardous materials in commerce is by requiring the use of the four hazard communication methods:

  1. HazMat Labels
  2. Markings
  3. Shipping Papers
  4. Placards
vehicle transporting Division 2.2 non-flammable gas
Parked behind a strip mall of restaurants in Longmont, CO

In this article I’ll take an example of HazMat transportation selected right from daily life and use the hazard communication methods (those I have available to me) to discern just what the HazMat is and what its potential hazards are. (more…)

The Name of the Consignor (Shipper) or Consignee (Receiver) as a Marking on a HazMat Packaging

Unless an exception exists, the Hazardous Material Regulations (HMR) of the USDOT/PHMSA require the use of the four hazard communication methods when a hazardous material is offered for transportation; these are:

  • Shipping Papers
  • Placards
  • HazMat Labels
  • Markings

Markings are information affixed to the outside of the package, freight container, or transport vehicle used to communicate information about the hazardous material inside.  This article will explore one of the requirements for marking a non-bulk HazMat packaging: the  consignee’s or consignor’s name and address. (more…)

Identification number for a Class 9 liquid

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.

 

USDOT/PHMSA Releases Brand New DOT Chart 15

Just like Nigel Tufnel’s amp that went up to 11, the new DOT Chart 15 is one more than the DOT Chart 14 it just replaced, making it TWO more than the DOT Chart 13.  Whatever the number the DOT Chart 15 is the latest version of a guidance document created by the PHMSA of the USDOT.  It contains a wealth of information – both text and images – of three of the four hazard communication methods (Markings, HazMat Labels, & Placards; only Shipping Papers are missing) and is invaluable to anyone involved in the transportation of hazardous materials:  shippers, carriers, receivers, HazMat Employers, HazMat Employees, training providers, etc.  Given the amount of helpful information it contains regarding the hazardous material regulations (HMR) it is hard to believe that it is only four pages.  The purpose of this article is to briefly explain the content in a DOT Chart 15 to the uninitiated and to provide direction to where you may obtain copies of it for yourself. (more…)