The determination of the placarding requirements for a shipment of hazardous materials (found at 49 CFR 172, Subpart F) are, initially, straightforward. Placarding of a transport vehicle or freight container to be transported by highway or rail is required for…
- Any quantity of a hazardous material found in Table 1 of the Placarding Tables.
- Any quantity of a hazardous material found in Table 2 of the Placarding Tables in a bulk packaging.
- When the aggregate gross weight of all Table 2 hazardous materials in non-bulk packagings in the transport vehicle or freight container is ≥1,001 lbs.
But of course, it gets more complicated from there. You may be surprised to learn that 49 CFR 172.502(c) allows for the display of placards for a hazardous material even when not required by regulation, if the placarding otherwise conforms to the requirements of 49 CFR 172, Subpart F.
So, this means that even if none of the conditions in #’s 1-3 above are met, a carrier may desire to display placards on a shipment of hazardous materials and this will not be in violation of the Hazardous Materials Regulations (HMR).
The HMR are filled with little exceptions and restrictions just like this one. Make certain you and your HazMat Employees have received the training required by 49 CFR 172, Subpart H to ensure they maintain your company’s regulatory compliance. Contact me for a free consultation on your training needs.