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

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.
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:

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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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: Are placards required for the transport of this two-part resin system?

A question from someone who had recently attended one of my USDOT/PHMSA HazMat Employee Training Webinars (05.17.18):

Hi Daniel!

We have a product in totes (Product Name part A, ###A) which is a DOT HazMat class 9 (UN: NA3082, PG III, liquid) with an RQ of 11,111 lbs. In Section 14 of the SDS it states: “When in individual containers of less than the Product RQ, this material ships as non-regulated” – I’m not sure what this means. The product is shipped in totes/IBC (each approx. 3300 lbs – 330 gal) with about 4-6 per load.

My question is: does a semi truck trailer need to be placarded (class 9) when shipping about 4-6 totes (total max ~22,000 lbs; in bulk and >1,001 lbs)? According to your USDOT/PHMSA HazMat Employee training webinar I recently attended, placarding is required for any materials from Table 2 in bulk package (>119 gal) or >1,001 lbs. Also, on page 3 of the DOT Chart 16 (handout) it states for CLASS 9: “(Placarding) Not required for domestic transportation”.

Could you clarify this? No need to elaborate much, I’m just looking for the quick answer. The confusing part is the SDS statement…. and Chart 16.

Thank you very much!!

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A quick reply based on the available information:

Please see below.

Section 14 of the SDS cannot be relied upon for a hazmat classification. Read: Section 14 of the SDS, can it help with your HazMat Classification?
I am not aware of any hazardous substance with a reportable quantity (RQ) of 11,111 lbs. I believe the max RQ is 5,000 lbs.
It would be helpful to know the constituent in the product that is a hazardous substance. Can you provide an SDS for the product?
I won’t know for certain without seeing the SDS but I am confident the statement in section 14 is indicating that the material is not regulated as a HazMat unless it is a RQ of a hazardous substance.
If I knew the name of the HazMat and its concentration in the solution, I could determine if an RQ of a hazardous substance is present.
The Class 9 Miscellaneous placard is not required within the U.S.

I think a quick review of the SDS would indicate if a hazmat or not.

He was able to provide additional information:

Class 9 Miscellaneous placard

Here is page 1 and page 10 of the SDS. Sorry for the poor quality of the image.

Thanks again!

Note from Daniels Training Services: I did not include the images but below is the relevant content.

Text from section 14 SDS reads: “Additional Transportation Information: When in individual containers of less than the product RQ, this materials ships as non-regulated.”
The hazardous substance component of the product was 4,4′-diphenylmethane Diisocyanate (MDI). It has a RQ of 5,000 lb.
The information provided did not identify the concentration of MDI in the product.
As noted in the previous email, it is not required to display the Class 9 Miscellaneous placard in the U.S.

My reply:

Please see below. My response is based on the information provided.

Do not rely on section 14 of this SDS. In this SDS it contains several errors. Unfortunately, this is not uncommon in my experience.
The product is only a hazardous substance if at a concentration of 10% or more in the solution and has a mass of 5,000 lbs (454 kg) or more in a single container. This is not possible in a single IBC of 3,300 lbs.
It does not appear to be a HazMat for any other reason that I can determine. However, it may contain other HazMat I am not aware from the information provided.

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He sought confirmation:

No need to placard trucks transporting this material then. Thanks for the clarification.

My final answer with a suggestion:

No, however, I do think this deserves more research. In my experience at least one of the two parts of a resin system are a HazMat.

Conclusion:

But that was the last I heard from him on that topic.

Q&A: Which are required to be displayed on IBCs: placards or labels?

A question from a repeat customer on June 8, 2017. (I’m frequently contacted by customers in the interim between their periodic training to answer questions).

Hi Dan,

I hope this finds you doing well.

During the training session back in April, there was a question raised about “do we need to apply a placard to IBCs or can we use the 4” x 4” labels”. I cannot remember what the answer to this question was.

We ship a number of IBCs of class 8 material not only domestically but also via ocean and today we place a class 8 placard on opposing sides of the IBC. Is this required or can we use the smaller 4” x 4” class 8 label?

Thanks for the help.

Best regards,

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

My reply that same day:

Thank you for contacting me.

I can answer part of your question now. The other part will take more time and research. Please see below.

For transportation within the U.S. according to the regulations of PHMSA, there are several options for the marking, labeling, and/or placarding of an IBC. One option available is to mark and label the IBC in the same manner as a non-bulk packaging. This means a single HazMat label (4″ x 4″) near the proper shipping name and the identification number (ID number at least 12 mm high). This article I wrote explains the available options, including the above: How to Mark, Label, and/or Placard an IBC of HazMat.
The requirements for hazard communication on an IBC per the regulations of the IMO are not immediately known to me. I will need to research the answer and reply.

I hope this helps.

He was grateful, but I wasn’t done!

Thanks Dan!!

It took me until the next day to research the Dangerous Goods Code of the International Maritime Organization (IMDG Code):

I now have an answer to the second part of your question. Please see below.

Per the IMDG Code, an IBC of more than 450 L (119 gal) must be marked on two opposing sides (5.2.1.4) and must be labeled on two opposing sides (5.2.2.1.7).
This differs from the domestic regulations of PHMSA which has many options but includes an option to label and mark on only one side.

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

His reply the same day (06.09.17):

Hi Daniel,

Thanks for this information. The last part of our question relates to the size. Today we place a placard on each side of the tote but we are wondering if we can use a 4” x 4” label instead. This would be easier and less costly.

Thanks again.

I wished to clarify the information:

In both instances (domestic and international) a 250 mm x 250 mm (approximately 4″ x 4″) HazMat label is acceptable.

Wow! Look at all those exclamation marks! I think I helped him to save his company a lot of money!

Thanks!!!!!!

Interested in site specific training at your site that covers this topic, and more!

Ask me about my Onsite Training

Conclusion:

This exchange illustrates several important points about the applicable regulations and my services:

The transportation of hazardous materials is subject to a variety of regulations based on its mode – aircraft, vessel, rail, or highway – and its destination – domestic or international.
My International Maritime Organization (IMO) training will meet the requirements of the regulations and will inform you of ways that you can comply with the regulations and save money.
It costs money to comply with the regulations but there are ways for a business to save money without violating the regulations. The options available for the labeling, marking, and/or placarding of IBCs is just one example of that.

Placarding for Subsidiary Hazards

The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) mandate the display of placards on certain vehicles and packagings when they contain a hazardous material (HazMat). Compliance is relatively simple if the HazMat has only one hazard. But what of a HazMat with a subsidiary hazard – or two! The purpose of this article is to identify and explain the USDOT/PHMSA regulations for the display of placards of a subsidiary hazard. (more…)

Visibility Requirements for Hazardous Material Placards on a Rail Car

In the general placarding requirements of 49 CFR 172.504(a) of the USDOT/PHMSA Hazardous Materials Regulations (HMR), it states that when required each bulk packaging, freight container, unit load device, transport vehicle, or rail car “must be placarded on each side and each end”. Simple enough, right?

It becomes more complicated when we consider the visibility and display of those placards on a motor vehicle or rail car.

The purpose of this article is to address solely the requirements of the HMR at §172.516(a) for the display of placards on a rail car.

The display of placards on a rail car (and motor vehicle & transport vehicle) is addressed in §172.516(a). (I have added emphasis):

Each placard on a motor vehicle and each placard on a rail car must be clearly visible from the direction it faces, except from the direction of another transport vehicle or rail car to which the motor vehicle or rail car is coupled. This requirement may be met by the placards displayed on the freight containers or portable tanks loaded on a motor vehicle or rail car.

We begin back in §172.504(a) where it states that if required a rail car must be placarded on each side and each end. Easy. However, §172.516(a) tells us that the placard must be clearly visible from the direction it faces. That means a placard should be clearly visible to a person standing on the side of the rail car on which it is displayed.

However, this requirement for visibility need not be met when the placard is displayed on either end of a rail car that is coupled to another rail car. This means that the placards on the ends (front and back) of a rail car must be present, but need not be clearly visible if the rail car is coupled to another rail car.

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

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Below are images of tank cars in a train displaying placards on their sides (clearly visible) and ends (not so clearly visible).

: Each tank car is a separate transport vehicle

: UN3256, Elevated temperature liquid, flammable, n.o.s.

Since the tank car is a type of rail car and it contains the hazardous material, the placarding requirement is met by its display of the placard. But what if the hazardous material is contained in a portable tank or freight container that is then carried by a flat car (another type of rail car)? §172.516(a) goes on to state that – if loaded on a rail car – the display of placards on a freight container or portable tank will meet the requirements.

Below is an image of freight containers on rail cars (flat cars) displaying placards on their sides (clearly visible) and ends (not so clearly visible). Per 172.516(a) it is perfectly acceptable that the placards are displayed on the freight container and not on the rail car itself.

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The display of placards on a motor vehicle / transport vehicle presents more of a challenge, but that will be addressed in a later article.

You may also be interested in this article on the General Display Requirements for Placards.

If you’re interested in the display of placards on a rail car you may also be interested in the USDOT/PHMSA HazMat Employee training that I provide. Please contact me for a free discussion and/or estimate.

Q&A: Do I have to placard the vehicle if placards are visible on IBCs?

A question (09.22.17):

if you are carrying 2 – totes of sulfuric acid on flatbed rail side truck and the totes are placarded correctly with the un# bulk placards. Does the truck also have to be placarded with the same placards?

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

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Daniels Training Services, Inc.

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My answer:

The answer to your question is yes, the truck must display the required placards in addition to those on the totes if by “tote” you mean an intermediate bulk container or IBC and not a portable tank as your subject line indicates. Please see below.

49 CFR 172.504(a) requires a transport vehicle to display placards on all four sides (i.e. each side and each end) unless the type and quantity of HazMat is excepted from placarding requirements. This is not the case in your scenario.
49 CFR 172.516(a) requires the placards on a vehicle to be clearly visible and allows the required display of placards to be replaced by their display on a freight container or portable tank. An IBC is not indicated as an option for this exception.
49 CFR 171.8 defines a freight container: 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.
49 CFR 171.8 defines a portable tank: Portable tank means a bulk packaging (except a cylinder having a water capacity of 1000 pounds or less) designed primarily to be loaded onto, or on, or temporarily attached to a transport vehicle or ship and equipped with skids, mountings, or accessories to facilitate handling of the tank by mechanical means. It does not include a cargo tank, tank car, multi-unit tank car tank, or trailer carrying 3AX, 3AAX, or 3T cylinders.
49 CFR 171.8 specifically defines an IBC as not a portable tank.

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In sum:

The display of placards and package marks (the 4-digit identification number) on the tote (aka: IBC) does not fulfill the requirement to display placards on all four sides of the vehicle.

Conclusion:

I receive questions like this all the time. Sometimes – like this one – I’m surprised by the answer. Make sure you know the regulations before you ship and risk a fine. Contact me with your questions.

Q&A: Is my tote a bulk packaging? Is it subject to regulation when shipped empty?

A question from a former coworker on August 29, 2017:

Good morning Dan. We have a client that has soaps coming to the facility that are corrosive in totes. They have contracted a recycling service to come pick up the empty totes. The service provider is being very conservative and wants to ship the totes as hazardous material, even though the totes are empty by normal practical means. They are stating the totes are 150 pounds each so when over six are shipped they are asking the client to provide placards for the shipment. The client is not DOT registered, they normally do not offer hazardous substances for transportation. Does the client take on liability for misrepresenting the shipment? (should not be shipped as a hazardous substance) I assume they would need to become registered and pay the annual fee, correct? If they only ship six totes (900 pounds), they would not require placarding and therefore would not need to be registered. However, if the transporter still wants to ship with a placard, could the client be responsible for misrepresenting the load by providing placards and signing shipping papers? Where is this addressed in the rules?

My reply that same day:

Thanks for contacting me.

Unless, “sufficiently cleaned of residue and purged of vapors to remove any potential hazard…” the packaging is subject to full regulation as a hazardous material when offered for transportation. Read: “Emptying” a Hazardous Material Packaging. 49 CFR 172.514(b) states this clearly for a bulk packaging.
There is an exception from full regulation for “empty” packagings that contain HazMat residue. However, this exception does not apply to a bulk packaging. I assume the “tote” you refer to is a bulk packaging. Read: Bulk Packaging for HazMat Explained!
Therefore, a bulk packaging containing any residue of a hazardous material must be shipped as a fully regulated HazMat. This means that HazMat labels, marks, and/or placards are required on the packaging and on the vehicle as applicable. A shipping paper describing the hazardous material must accompany the shipment. All personnel involved in its off-site transportation must receive HazMat Employee training.
Any amount of a HazMat in a bulk packaging requires the display of placards on the vehicle. It does not matter the weight of the HazMat nor the number of bulk packagings. 49 CFR 172.504(c) offers an exception for display of placards on a vehicle but not for bulk packagings or the really nasty HazMat of Placarding Table 1 at 49 CFR 172.504(e).
The shipper is responsible for the classification and shipment of the HazMat in compliance with the Hazardous Materials Regulations. They will get the fine, not the carrier.

Options:

Ship empty totes as fully regulated HazMat.
Rinse out totes so no hazard remains. Discharge wastewater down drain to POTW. Then offer for transport. No hazardous residue = no HazMat regulations.
Add chemical and/or absorbent to totes to neutralize Class 8 Corrosive. No hazardous residue = no HazMat regulations.

Hope this helps. Please contact me with any questions.

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It may not have been the answer he was hoping for but it did help:

Thank you so much Dan. I didn’t realize the totes were considered bulk packages and the “empty” definition does not apply. I’ve not really worked much with totes and I have learned something new again.

This really helps. Thank you.

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