Placards

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:

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

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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: Is it necessary to display placards if I’m hauling 2,205 lb of just one type of HazMat (Division 2.2)?

Question1:

Hello,

I was hoping to get some clarification on this. I have highlighted the section in red that I am questioning. If I have less than 2,205lbs of just one type of hazard identified in table 2, non-flammable gas 2.2 to be exact, then it doesn’t need to be placarded? Or does it if it is over 1,001 lbs? It seems like the 1,001 lbs rule applies if you are combining 2 or more hazards identified in table 2?

https://www.govregs.com/regulations/49/172.504

(b) DANGEROUS placard. A freight container, unit load device, transport vehicle, or rail car which contains non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of this section may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in table 2 of paragraph (e) of this section. However, when 1,000 kg (2,205 pounds) aggregate gross weight or more of one category of material is loaded therein at one loading facility on a freight container, unit load device, transport vehicle, or rail car, the placard specified in table 2 of paragraph (e) of this section for that category must be applied.

(c) Exception for less than 454 kg (1,001 pounds). Except for bulk packagings and hazardous materials subject to § 172.505, when hazardous materials covered by table 2 of this section are transported by highway or rail, placards are not required on

(1) A transport vehicle or freight container which contains less than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by table 2 of paragraph (e) of this section; or

(2) A rail car loaded with transport vehicles or freight containers, none of which is required to be placarded.

Answer1:

Thank you for contacting me. I will try to answer your question below.Dangerous placard

  • The text highlighted in red applies to two separate placarding scenarios.
  • 49 CFR 172.504(b) applies to the use of the DANGEROUS placard.
  • §172.504(c) is an exception from the general placarding requirements of §172.504(a).
  • If a vehicle contains less than 454 kg (1,001 lb) of a table 2 HazMat (e.g., Division 2.2), in a non-bulk packaging, placards are not required to be displayed on the vehicle.
  • The DANGEROUS placard may be used when two or more HazMat of Table 2 in non-bulk packaging that require the display of placards are transported at the same time. The text you highlight in red states that if 1000 kg (2,205 lb) of HazMat is loaded at one facility, it must be placarded separately (per its own placarding requirements) and is not covered by the DANGEROUS placard.

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

Question2:

Daniel,

Thank you for your response. So you are saying as long as we have under 1001 lb. of 2.2 cylinders we do not have to placard? Each cylinder weighs 60lbs. If we go over that weight threshold then we would have to placard? Can you have 1001lb in a pickup and 1001lb in a trailer behind it? Or 1001lb per combination?

Thanks!

Answer2:

Please see below.

  • Correct. The placarding threshold for a Division 2.2 in a non-bulk packaging is 454 kg (1,001 lb) or more.
  • A pickup towing a trailer are subject to the USDOT/PHMSA Hazardous Materials Regulations as two separate transport vehicles. Each with its own placarding requirement. Therefore, if you had 1,000 lb of Division 2.2 in the pickup and 1,000 lb of Division 2.2 in the trailer (both in non-bulk packagings) then no placards are required on either.
  • A person operating a vehicle that does not require the display of placards does not require the HazMat endorsement on their CDL. They would require HazMat Employee Training with the additional component of Driver Training.

Contact me the next time your USDOT/PHMSA training is due to expire.

Please contact me with any other questions.

Conclusion:

 

Q&A: If our shipments never require placards do we need to have placards available?

Q&A: If our shipments never require placards do we need to have placards available?

Question:

If our shipments never require placards do we need to have placards available?

Answer:

That’s a good question. Please see below.

  • The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety administration within the U.S. Department of Transportation (USDOT/PHMSA) require the shipper to provide placards to the driver unless the motor vehicle already displays the required placards. [49 CFR 172.506(a)]
  • A shipper that offers hazardous materials (HazMat) for transportation in quantities that require the display of placards on the vehicle should therefore have a supply of the applicable placards in order to be able to provide them to the carrier if necessary.
  • Nowhere does the HMR require the shipper to maintain a supply of placards.
  • I have read of a shipper fined because it did not have a supply of placards for the HazMat they shipped. Unfortunately, I don’t have documentation for this.
  • If you do not ship any HazMat that requires the display of placards, then you will never be required to provide placards to the driver and therefore you are not required to maintain a supply of them.
  • Also, the requirement to provide placards to the driver at 49 CFR 172.506(a) applies solely to the HazMat you offer for transport, not to the combination of your HazMat and what is currently or will later be loaded on the vehicle.

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

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  • Note: even though the consignment does not require the display of placards, the requirement to provide HazMat Employee training for personnel with a direct affect on its safe transportation remains.
  • In conclusion: No. A shipper is not required to maintain a supply of placards regardless of whether or not it may offer for transport a type or quantity of HazMat that requires the display of placards.

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

Q&A: Who is responsible for removing the placards from a freight container once transport of HazMat is complete?

Q&A: Who is responsible for removing the placards from a freight container once transport of HazMat is complete?

It all began with a telephone call on November 18, 2020:

We receive hazardous materials delivered to our facility in a freight container. The freight container displays the required placards. The carrier deposits the freight container at our facility and departs. We unload the HazMat from the freight container over the next few hours. When making the next delivery the carrier retrieves the now empty freight container and take it I know not where.

cargo transport unit

A freight container

It is been an ongoing argument with the carrier as to who is responsible for removing the placards from the empty freight container. They are displayed so high on the freight container that any effort by us to remove or deface them requires use of a ladder and safety issues we don’t wish to deal with. The driver refuses to remove the placards. The carrier will not pick up the empty freight container unless all of the placards are removed or covered up.

What are our options? Can the empty freight container be transported with the placards displayed? Are we responsible for removal of the placards? Or, is it the responsibility of the driver / carrier?

Please help us resolve this issue!

My reply:

Thank you for contacting me. Please see below for guidance:

  • Unfortunately, there are no clear directions in the hazardous Materials Regulations (HMR) to indicate who is responsible for the removal of hazard communication (e.g., placards, marks, labels) from any HazMat packaging or the freight container. However, 49 CFR 171.2 requires all forms of hazard communication to be removed from a package or vehicle if the HazMat is no longer present. Thus, all placards must be removed prior to transportation of the empty freight container. (LOI 03-0251)
  • Most responsibilities for the preparation of a HazMat and its packaging for transportation fall on the shipper (aka; the person who offers or the offeror of the HazMat). In this situation the empty freight container is being re-offered for transportation. It is the person who re-offers it for transportation that must ensure any existing placards not applicable to the current load are removed. (LOI 05-0050)

So…

  • The placards must be removed prior to transportation of the empty freight container.
  • This must be done by the person who re-offers the freight container for transport (i.e., the shipper).

Answer: It depends. Whoever arranges for the transport of the freight container once empty is the shipper and is therefore responsible for removal of the placards unless they have an agreement with someone else, e.g., the carrier or some other third party, who will perform all the responsibilities of the shipper or just that specific function.

It is not a clear-cut answer, but I think it is all we will get.

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Conclusion:

Unfortunately, the requirements, responsibilities, and directives of the HMR are not always clear. In this situation, it hinges on one question: “Who is the shipper?” If you are the shipper of a HazMat, the carrier, or simply receive HazMat, you are subject to the regulations of the USDOT/PHMSA and require some form of HazMat Employee training.

Q&A: May I transport an empty cargo tank when I don’t have the HazMat endorsement on my CDL?

A question, September 16, 2020:

Subject: placards

Message Body:
Sir:    If i pick up a propane truck (26,000 lb) with a new tank on it from the factory and it has the sticky placards on it can i cover them up to transport the truck to the destination?   I have a tank endorsement but no hazmat.  thank you.

My reply that same day:

As long as the cargo tank does not contain any HazMat at all. Not even the residue of the HazMat. Not even vapors. If you open the cargo tank and smell nothing but that fresh factory smell, then yes, you must cover up or remove the placards during transportation.

If any residue of the HazMat remains – even just vapors – then transport must be as fully-regulated, including the HazMat Endorsement on the CDL.

I hope this helps.

Please read:

Please contact me with any other questions.

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He had one more question for me (09.21.20):

I have one more question for you if you don’t mind. Can a state superseded any hazmat laws? If so would you have any idea what the fine would be?Also would the drivers license would be impacted if he violates any hazmat laws? Thanks again for your help.

I had another reply:

Good questions. See below.

  • The Hazardous Materials Regulations for HazMat transportation (including placards) are Federal. They are created by the Pipeline and Hazardous Materials Safety Administration within the US Department of Transportation (USDOT/PHMSA). States may not change them in any way, though a state may enforce the Federal regulations and issue state fines.
  • The commercial driver’s license (CDL) is issued by the state with both Federal and state requirements. Federal authority is under the Federal Motor Carrier Safety Administration within the USDOT (USDOT/FMCSA).
  • I don’t think – I am not entirely sure – violation of HazMat regulations will result in loss of CDL unless the violation is viewed to be criminal. The regulations of the FMCSA identify the ways a driver can lose their CDL and none of them are HazMat violations.

Other subjects related to HazMat and the CDL:

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That seemed to do it:

Thank you for the clarification.

Q&A: Do I have to placard bulk tanks when they’re empty?

Q&A: Do I have to placard bulk tanks when they’re empty?

The question, November 05, 2020:

Good afternoon,

I have a question about carrying bulk tanks. I recently got stop and was told that I was in violation because I didn’t have my placards showing with flammable material. I told the DOT officer that my bulk tanks were empty and that to my understanding that once you are empty you cant show your placards as flammable anymore. Well, long story short I got a ticket for not showing my placards as flammable even though the totes were empty.

My question is… Is he correct on this?

Thank you,

Daniels Training Services, Inc.

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My reply that same day:

The answer depends on two factors:

  • Are the “bulk tanks” or “totes” you refer to a bulk packaging? I presume they are.
  • Are the bulk tanks / totes empty to the point where they are sufficiently cleaned of residue and purged of vapors to remove any potential hazard per 49 CFR 173.29(b)(2)(ii)? I presume they are not and still contain some residue of the HazMat.

If this situation involves a bulk packaging that still contains the residue of a Class 3 Flammable Liquid (even just vapors), then – unfortunately – the DOT officer is correct in that the packaging must continue to display the placards it was required to display when full. In fact, the entire consignment is subject to full regulation, which requires:

There is an exception from full USDOT regulations for an empty packaging with residue but this exception does not apply to a bulk packaging like your totes.

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

Interested in a Webinar that covers this topic, and more!

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Conclusion:

Probably didn’t help him much since he already had the ticket. But, better to be sure for next time.

Contact me before you or one of your drivers are ticketed by USDOT for a HazMat transportation violation.

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: Do I placard for a Class 3 Flammable in bulk packaging and 500 lbs of a Class 8 Corrosive in non-bulk?

Q&A: Do I placard for a Class 3 Flammable in bulk packaging and 500 lbs of a Class 8 Corrosive in non-bulk?

A follow-up question from a occasional contact (06.13.18):

Daniel, Hope all is doing well.

I have another question that has been bothering me as well.  Hoping you can share some guidance.

Say I have a shipment of UN1993 BULK(ONE TOTE BIN)

I also have a shipment of Corrosive UN1806 non-bulk weighing 500lbs.

No other hazmat on board.  How would this trailer be placarded?

I, myself would say a bulk UN1993 placard and a corrosive placard.

I have had other safety officials advise that the bulk shipment is not included on the aggregate gross weight once its placarded.

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My reply several days later:

I have an answer and it is not what I initially anticipated (I’m glad I did additional research of 49 CFR 172.504(c)).  Please see below.

  • When determining the placarding requirements for a vehicle there are three criteria to consider (other exceptions are available but not applicable to this scenario):
    1. Is it any quantity, any packaging of a HazMat identified in Table 1 at §172.504(e)?  If so, placard for hazard class.
    2. Is it any quantity of HazMat identified in Table 2 at §172.504(e) in a bulk packaging?  If so, placard for hazard class.
    3. Is it any single or multiple HazMat of an aggregate gross weight of 454 kg (1,001 lbs) or more ?  If so, placard for each hazard class.
  • The above criteria are considered independently.  Therefore, the weight of a Table 2 HazMat in a bulk packaging (which requires display of the placard for its hazard class according to #2 of the above) is not counted toward the aggregate gross weight threshold indicated in #3.  Similarly, the weight of a Table 1 HazMat (placards required according to #1 of the above) is not counted toward the aggregate gross weight threshold of #3.
  • Separate from the regulations for the display of placards are those that require the display of the identification number on transport vehicles and freight containers.  A vehicle transporting a bulk packaging (e.g., an intermediate bulk container or tote bin), must display the HazMat’s identification number unless the number is visible on the packaging during transport.

In your scenario the vehicle must display the Class 3 placard with the identification number (1993) – because it is in a bulk packaging – but not the Class 8 placard – because it’s gross aggregate weight (not counting the Class 3 tote) is <454 kg (1,001 lbs).  Of, course, the driver has the option to display the Class 8 placard if they so choose.

This letter of interpretation from USDOT/PHMSA almost exactly represents your scenario:  LOI 02-0043.

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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Info@DanielsTraining.com

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And that did it.

The regulations for the display of placards on a vehicle can be simple, but can become more complex when the hazardous materials transported and the types of packagings used increase.  Make certain your placards are correct and are displayed properly.

Q&A: My truck has Corrosive, Combustible Liquid, and Class 9 Miscellaneous. What placards are required?

Q&A: My truck has Corrosive, Combustible Liquid, and Class 9 Miscellaneous. What placards are required?

A question from a recent customer (June 06, 2018):

Daniel,

Hope this finds you well. I am the warehouse manager at <<Company>>. I was wondering if you can clear something up for us. When placarding trucks if we have multiple hazard classes shipping and it is over 1000# we have to placard all the hazard classes correct? If you look at the attachment I believe we should’ve placarded both class 8 & 9. (A shipping paper was attached showing a consignment of more than 2,500 lb of various Class 8 Corrosive Materials, more than 3,000 lbs of a Class 9 Miscellaneous, 220 lb of a Class 3 Combustible Liquid, and some non-hazardous materials).  I have some that believe if one class is over the 1000# that is what gets placarded. Would you be kind enough to help clear this confusion.

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.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
My reply:

Thank you for contacting me.  Based on the available information I have made the following determination.  Please see below.

  • The consignment contains both HazMat & non-HazMat.  The non-HazMat is not counted toward the placarding threshold.
  • The HazMat is of three types:  Class 8 Corrosive, Class 9 Miscellaneous, & Class 3 Combustible Liquid.
  • All are in a non-bulk packaging.
  • 49 CFR 172.504(a) indicates it is necessary to display placards on a vehicle containing any amount of a hazardous material except in the following conditions:
    • A hazardous material identified in Table 2 of the placarding tables at §172.504(e), in a non-bulk packaging, if the total amount of HazMat in the vehicle is less than 454 kg (1,001 lb).
  • Since neither the Class 9 Miscellaneous nor the Class 3 Combustible Liquid in a non-bulk packaging are required to display placards, their respective weight is not counted toward the placarding threshold.
    • This letter of interpretation from USDOT/PHMSA (97-0099) is too old to be available as a link from their website.  However, it indicates that Class 9 Miscellaneous HazMat is not counted toward the placarding threshold:  “Only materials that are covered by Table 2 and that require placarding are included in the aggregate gross weight.”  Though not stated directly, this would apply to Class 3 Combustible Liquids in a non-bulk packaging as well.
    • Read:  Is the Class 9 Placard Required?
    • Read:  USDOT Exception for Combustible Liquid HazMat
  • If the weight of the Class 8 Corrosive is 454 kg (1,001 lbs) or more, then it is necessary to display the Class 8 Corrosive placard on the vehicle.hinged placard
  • Display of the Class 9 Miscellaneous and the Class 3 Combustible Liquid placards on the vehicle are optional – at the discretion of the driver – but not required.

I hope this helps.

Please contact me with any other questions.

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And that did it!

This absolutely helps. Thank you for this info.

Q&A: I’m picking up Class 8 Corrosive and Class 9 Miscellaneous (Marine Pollutants). What placards do I need?

Q&A: I’m picking up Class 8 Corrosive and Class 9 Miscellaneous (Marine Pollutants). What placards do I need?

Sent May 05, 2018, all in uppercase so I knew he was serious.

TUESDAY I HAVE TO PICK UP 9,000 LBS OF CLASS 8 MATERIALS IN 200 BOXES ON 10 PALLETS PLUS 50 BAGS ON 2 PALLETS AT 1500 LBS OF CLASS 9 MARINE POLLUTANT MATERIALS.
DO I NEED A CORROSIVE PLACARDS WITH THE UN NUMBER ON THEM AND MARINE POLLUTANT PLACARDS FOR MY TRAILER?
I REFUSED THIS LOAD FRIDAY FOR THE LEAKING OF ONE BAG OF THE MARINE POLLUTANTS AND NO HAZMAT DOCUMENTS FOR THE CLASS 8 BOXES.

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My reply the next day:

Thank you for contacting me.  I will answer your question below:

  • You were correct to reject the original consignment due to damaged packaging and lack of hazardous material shipping paper.  Per 49 CFR 177.801:

No person may accept for transportation or transport by motor vehicle a forbidden material or hazardous material that is not prepared in accordance with the requirements of this subchapter.

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

That must have done it because I didn’t hear from him after that.

Contact me the next time your USDOT Training is due to expire.