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).

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!!

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:

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

Thanks again!

• 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.

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.

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,

My reply that same day:

Thank you for contacting me.

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…)

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.

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

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.

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.