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.

Note:  terms in italics are defined at 49 CFR 171.8 of the HMR.

UN2693, Bisulfites, aqueous solutions, n.o.s

Notes on this image:

The vehicle:

• The type of vehicle, though commonly referred to as a “tanker truck” or “tank truck”, is identified in the HMR as follows:
  • As a type of cargo-carrying vehicle it is a transport vehicle.
  • Because it is a vehicle operating on a highway (any public road) it is a motor vehicle.
  • The packaging for the hazmat is a cargo tank, a type of bulk packaging.  It is intended primarily for the transport of liquids or gases.
  • A motor vehicle with a cargo tank (as shown in this picture) is identified in the HMR as a cargo tank motor vehicle.
• Because the motor vehicle is transporting a quantity of hazmat that requires the display of placards it is defined by the Federal Motor Carrier Safety Administration (FMCSA), another administration within the USDOT, as a commercial motor vehicle.

The placard(s):

• The placard displayed is for Class 8 Corrosive Material.
• A Class 8 Corrosive Material may be an acid or a base, a liquid (as I presume it is here) or a solid.
• Read:  The General Requirements for Display of HazMat Placards.
• When required, placards must be displayed and visible on all four sides of the cargo tank or motor vehicle.
• The placard required to be displayed on the front of the cargo tank or motor vehicle may be displayed on the front of the truck-tractor instead of or in addition to the placard on the front of the cargo tank.
• A cargo tank – as all other bulk packagings – must display the applicable placards if it contains any quantity – even vapors – of a hazmat.  In other words, the cargo tank in these pictures may be “empty”.  Read more about the HMR and “empty” packagings.
• It is the responsibility of the shipper to offer the correct placards to the driver of the motor vehicle.  Read:  Shipper of HazMat’s Responsibility to Offer Placards to the Driver.

The identification number:

• The identification number displayed (UN2693) identifies the proper shipping name of the hazmat as: Bisulfites, aqueous solutions, n.o.s.
• The identification number – without “UN” or “NA” – must be displayed on all four sides of a cargo tank of this volume.
• The identification number must be displayed on or near the placard.
• The display of the identification number on the placard – as in this picture – is only one option for its display; there are two others:
  • On an orange panel near the placard.
  • On a white square-on-point near the placard.  Note: though the white square-on-point must have the same dimensions as a placard it is not a placard, it is a package mark or marking.
• A cargo tank – as for any other bulk packaging – must continue to display the applicable identification number if it contains any quantity – even vapors – of a hazmat.  In other words, the cargo tank in these pictures may be “empty”.  Read more about the HMR and “empty” packagings.
• It is the responsibility of the shipper to offer the correct identification number marking to the driver of the motor vehicle.

Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://www.danielstraining.com/

DANGEROUS Placard only:

The vehicle:

• As a type of cargo-carrying vehicle it is a transport vehicle.
• Because it is a vehicle operating on a highway (any public road) it is a motor vehicle.
• A semi-trailer (shown here) is one example of a motor vehicle.
• Because the motor vehicle is transporting a quantity of hazmat that requires the display of placards it is defined by the Federal Motor Carrier Safety Administration (FMCSA), another administration within the USDOT, as a commercial motor vehicle.

The placard(s):

• The placard displayed in these pictures is Dangerous.
• A Dangerous placard does not represent or identify a single hazard class or division of hazmat.  Therefore, the exact hazmat on the vehicle – type and quantity – is unknown.
• The Dangerous placard may be used only if all of the following are true:
  • Vehicle contains hazmat of two or more hazard classes or divisions that are of a type and/or quantity that requires placards.
  • Hazard classes must not be those found in Placarding Table 1 at 49 CFR 172.504(e).  Dangerous placard may be used only for the hazmat found in Placarding Table 2.
  • Hazmat represented by the Dangerous placard is in a non-bulk packaging.
  • The total weight of hazmat on the vehicle must be equal to or greater than the placarding threshold of 454 kg (1,001 lb).
  • Dangerous placard may only be displayed on a freight container, unit load device, transport vehicle (in the photos above), or rail car.
  • A Dangerous placard may not be used if 1,000 kg (2,205 lb) or more of a single hazmat from a single facility is loaded on or in the freight container, unit load device, transport vehicle, or rail car.
• Any hazmat not meeting the requirements for the Dangerous placard (i.e. bulk packaging, Placarding Table 1 hazmat, exceeds single pickup threshold, &etc.) must be represented by the display of the placard required for its hazmat.
• From the above conditions for use of the Dangerous placard, the following can be determined about the hazmat on this vehicle:
  • There is at least 1,001 lbs of hazmat, perhaps more.
  • There are at least two separate hazard classes that require placards.
  • None of the hazmat is in a bulk packaging.
  • No single hazmat of 1,000 kg or more was loaded from a single facility.
• Read more about the Dangerous placard.
• When required, the placard must be displayed and visible on all four sides of the transport vehicle.
• The placard for the front of the vehicle may be displayed on the front of the truck-tractor instead of or in addition to the placard on the front of the cargo body to which it is attached.
• It is the responsibility of the shipper to offer the correct placards to the driver of the motor vehicle.  Read:  Shipper of HazMat’s Responsibility to Offer Placards to the Driver.

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/

UN1789, Hydrochloric acid

Notes on this image:

The vehicle:

• The type of vehicle, though commonly referred to as a “tanker truck” or “tank truck”, is identified in the HMR as follows:
  • As a type of cargo-carrying vehicle it is a transport vehicle.
  • Because it is a vehicle operating on a highway (any public road) it is a motor vehicle.
  • The packaging for the hazmat is a cargo tank, a type of bulk packaging.  It is intended primarily for the transport of liquids or gases.
  • A motor vehicle with a cargo tank (as shown in this picture) is identified in the HMR as a cargo tank motor vehicle.
• Because the motor vehicle is transporting a quantity of hazmat that requires the display of placards it is defined by the Federal Motor Carrier Safety Administration (FMCSA), another administration within the USDOT, as a commercial motor vehicle.

The placard(s):

• The placard displayed is for Class 8 Corrosive Material.
• A Class 8 Corrosive Material may be an acid or a base, a liquid (as I presume it is here) or a solid.
• When required, placards must be displayed and visible on all four sides of the cargo tank or motor vehicle.
• The placard required to be displayed on the front of the cargo tank or motor vehicle may be displayed on the front of the truck-tractor instead of or in addition to the placard on the front of the cargo tank.
• A cargo tank – as all other bulk packagings – must display the applicable placards if it contains any quantity – even vapors – of a hazmat.  In other words, the cargo tank in these pictures may be “empty”.  Read more about the HMR and “empty” packagings.
• It is the responsibility of the shipper to offer the correct placards to the driver of the motor vehicle.  Read:  Shipper of HazMat’s Responsibility to Offer Placards to the Driver.

The identification number:

• The identification number displayed (UN1789) identifies the proper shipping name of the hazmat as: Hydrochloric acid.
• The identification number – without “UN” or “NA” – must be displayed on all four sides of a cargo tank of this volume.
• The identification number must be displayed on or near the placard.
• The display of the identification number on the placard – as in this picture – is only one option for its display; there are two others:
  • On an orange panel near the placard.
  • On a white square-on-point near the placard.  Note: though the white square-on-point must have the same dimensions as a placard it is not a placard, it is a package mark or marking.
• A cargo tank – as for any other bulk packaging – must continue to display the applicable identification number if it contains any quantity – even vapors – of a hazmat.  In other words, the cargo tank in these pictures may be “empty”.  Read more about the HMR and “empty” packagings.
• It is the responsibility of the shipper to offer the correct identification number marking to the driver of the motor vehicle.

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UN3077, Environmentally hazardous substance, solid, n.o.s., Marine Pollutant

The vehicle:

• The type of vehicle, though commonly referred to as a “tanker truck” or “tank truck”, is identified in the HMR as follows:
  • As a type of cargo-carrying vehicle it is a transport vehicle.
  • Because it is a vehicle operating on a highway (any public road) it is a motor vehicle.
  • The packaging for the hazmat is a cargo tank, a type of bulk packaging.  It is intended primarily for the transport of liquids or gases.
  • A motor vehicle with a cargo tank (as shown in this picture) is identified in the HMR as a cargo tank motor vehicle.
• Because the motor vehicle is transporting a quantity of hazmat that requires the display of placards it is defined by the Federal Motor Carrier Safety Administration (FMCSA), another administration within the USDOT, as a commercial motor vehicle.

The placard(s):

• The placard displayed in these pictures is for Class 9 Miscellaneous.
• Hazard class 9 Miscellaneous applies to materials that present a hazard in transportation but don’t meet the definition of any other hazard class.
• The display of the class 9 Miscellaneous placard is optional within the U.S.
• When required, placards must be displayed and visible on all four sides of the cargo tank or motor vehicle.
• The placard required to be displayed on the front of the cargo tank or motor vehicle may be displayed on the front of the truck-tractor instead of or in addition to the placard on the front of the cargo tank.
• A cargo tank – as all other bulk packagings – must display the applicable placards if it contains any quantity – even vapors – of a hazmat.  In other words, the cargo tank in these pictures may be “empty”.  Read more about the HMR and “empty” packagings.
• It is the responsibility of the shipper to offer the correct placards to the driver of the motor vehicle.  Read:  Shipper of HazMat’s Responsibility to Offer Placards to the Driver.

The identification number:

• Though the display of the Class 9 Miscellaneous placard is not required within the U.S., the identification number must be displayed.
• The identification number displayed (UN3077) identifies the proper shipping name of the hazmat as: Environmentally hazardous substance, solid, n.o.s.  Which is strange because…
• By definition at 49 CFR 171.8, a cargo tank is, “…intended primarily for the carriage of liquids or gases.”  So either there is a solid in this cargo tank (which is possible) or the wrong identification number is displayed.
• The correct identification number for an Environmentally hazardous substance, liquid, n.o.s. is UN3082.
• The identification number – without “UN” or “NA” – must be displayed on all four sides of a cargo tank of this volume.
• The identification number must be displayed on or near the placard.
• The display of the identification number on the placard – as in this picture – is only one option for its display; there are two others:
  • On an orange panel near the placard.
  • On a white square-on-point near the placard.  Note: though the white square-on-point must have the same dimensions as a placard it is not a placard, it is a package mark or marking.
• A cargo tank – as for any other bulk packaging – must continue to display the applicable identification number if it contains any quantity – even vapors – of a hazmat.  In other words, the cargo tank in these pictures may be “empty”.  Read more about the HMR and “empty” packagings.
• It is the responsibility of the shipper to offer the correct identification number marking to the driver of the motor vehicle.
• The “dead fish, dead tree” image is not a placard.  It is a package mark  or marking. It identifies the hazmat as a marine pollutant.  When displayed on a bulk packaging it must be the same size as a placard.
• What is a Marine Pollutant?
• The Marine Pollutant mark displayed here is allowed though not required.  Read: When is the Marine Pollutant Mark not Required?

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If you are interested in this article and these images, it is likely that in performing your job you have a direct impact on the safe transportation of hazardous materials.  If you do, then you are a HazMat Employee and require initial and triennial HazMat Employee training.  I can provide you – and all of your employees – with this training or provide consulting services or just answer any questions you may have about the safe transportation of hazardous materials in commerce.