PO Box 1232 Freeport, IL 61032

Placards

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?UN3266 in Intermediate Bulk Container (IBC)

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://danielstraining.com/

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:

hinged placardThe 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.UN3266 in Intermediate Bulk Container (IBC)
  • 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

Info@DanielsTraining.com

https://danielstraining.com/

What’s in/on those trucks?

The transportation of hazardous materials (hazmat) is all around us.  Below are images taken during my travels when I’ve come across the transportation in commerce of a hazmat.  In each situation I know little about the shipper or the carrier other than what I can read on the vehicle.  However, because the persons involved in the transport of these hazardous materials are trained HazMat Employees (along with an additional component of Safe Driver Training for the drivers) the vehicles and packagings display the hazard communication methods (placards and package marks) required by the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S Department of Transportation (USDOT/PHMSA).  It’s the display of these  hazard communication methods that allow me to determine the contents of the vehicles to the degree that I have in the images below.  Please read my comments related to each of the images and see if you agree with my conclusions. (more…)

What’s on/in those trucks?

The transportation of hazardous materials (hazmat) is all around us.  Below are images taken during my travels when I’ve come across the transportation in commerce of a hazmat.  In each situation I know little about the shipper or the carrier other than what I can read on the vehicle.  However, because the persons involved in the transport of these hazardous materials are trained HazMat Employees (along with an additional component of Safe Driver Training for the drivers) the vehicles and packagings display the hazard communication methods (placards and package marks) required by the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S Department of Transportation (USDOT/PHMSA).  It’s the display of these  hazard communication methods that allow me to determine the contents of the vehicles to the degree that I have in the images below.  Please read my comments related to each of the images and see if you agree with my conclusions. (more…)

Q&A: Must placards be affixed to a vehicle if visible on the packaging in transport?

Question from the HazMat transportation community (01.13.17):

Is it stated anywhere that the placards have to be mounted to the vehicle? If I’m carrying job site bulk tanks on a high flat can the tanks be visibly placard on 2 sides and front and rear or do placards need to be mounted on sides and rear and front of high flat?Bulk compressed gas cylinders of poison gas in transportation

Sent from my iPhone

My reply that same day:

Thank you for contacting me.

The quick answer is that as long as the placards are visible on all four sides of the vehicle it is not necessary to placard the vehicle as well.

I hope this helps.

Please don’t hesitate to contact me with any other questions.

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