Hazmat Rob’s Blog
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Every bulk package, transport vehicle, freight container and unit load device containing a hazardous material must be placarded. That is the rule. It’s the exceptions from the rule that everyone messes up. 49 CFR
is very specific about placarding under 172.504(a). The Department of Transportation Hazardous Materials
Regulations state that “each bulk packaging, freight container, unit load device, transport vehicle or rail car
containing any quantity of a hazardous material must be placarded on each side and each end with the
type of placards specified in Tables 1 and 2…”
But as we all know by now, there are exceptions to this rule, as with any government regulation. For example, Class 9 miscellaneous hazardous materials do not require placarding, but remember when shipping
bulk containers of Class 9, the bulk containers and the truck that contain them still must be marked with the
UN identification number.
Bulk containers are containers over 119 gallons (for liquids), 882 pounds (for solids) or 1000 gallons water
capacity (for gases). All bulk containers, affixed or visible, and transport vehicles containing any Table 1
or Table 2 hazardous materials require placards on all four sides. However, there is an exception for intermediate bulk containers (IBC’s) and portable tanks that weigh less than 1000 gallons each, which may be
Bulk containers are containers over 119 gallons (for liquids), 882 pounds (for solids) or 1000 gallons water
capacity (for gases). All bulk containers, affixed or visible, and transport vehicles containing any Table 1
or Table 2 hazardous materials require placards on all four sides. However, there is an exception for intermediate bulk containers (IBC’s) and portable tanks that weigh less than 1000 gallons each, which may be
placarded on only two opposite sides, even though the transport vehicles would still require placards on all
four sides for the bulk containers in the truck.
So if a driver had an IBC or tote filled with a Table 2 material like Acetone, Class 3, UN1090 in the back
of a semi tractor-trailer, the shipper could apply at least two Class 3 flammable liquid placards to the IBC,
and then offer four placards to the driver, for each side and end of his trailer. I really do not see a problem
placarding bulk containers regardless of whether they are Table 1 or Table 2, as long as all the containers
on the truck are bulk. And I do not see a problem with any Table 1 material when it comes to placarding,
because regardless of whether in bulk or non-bulk containers, Table 1 materials require the driver to affix
placards to all four sides of his truck.
The trouble starts when shipping Table 2 materials in non-bulk containers. Let me explain. If the vehicle
contains a single drum (non-bulk container) of Allyl Alcohol, which is a Table 1 with a primary hazard class
of Division 6.1, POISON BY INHALATION and a subsidiary hazard class of Class 3 flammable liquid, then
the drum would be required to display the poison inhalation and the flammable liquid 4×4 inch hazard class
labels in association with the UN number and shipping name. But because Allyl Alcohol is a Table 1 material, even though there is only a single drum on the truck, the truck would be required to display four 8×8 inch
primary hazard, Poison Inhalation Hazard, Division 6.1 placards, one on each side and each end. I think
most drivers and shippers know that regardless of whether you are shipping in bulk or non-bulk containers,
Table 1 materials must always be placarded.
In fact, I think that most drivers and shippers know that all Table 2 bulk containers
require placards (except Class 9). The trouble starts, as I mentioned, when
shippers and drivers come up against non-bulk containers of hazardous
materials listed in Table 2. If a driver were to read 49 CFR 172.504(a)
and the shipper to read 172.504(c) there could be a problem. This is
because 172.504(a) states any amount of hazardous materials in
a motor vehicle must be placarded. This would be 100% true if
not for 172.504(c), which states there are exceptions for less
than 1001 pounds of non-bulk containers of Table 2 materials:
most drivers and shippers know that regardless of whether you are shipping in bulk or non-bulk containers,
Table 1 materials must always be placarded.
In fact, I think that most drivers and shippers know that all Table 2 bulk containers
require placards (except Class 9). The trouble starts, as I mentioned, when
shippers and drivers come up against non-bulk containers of hazardous
materials listed in Table 2. If a driver were to read 49 CFR 172.504(a)
and the shipper to read 172.504(c) there could be a problem. This is
because 172.504(a) states any amount of hazardous materials in
a motor vehicle must be placarded. This would be 100% true if
not for 172.504(c), which states there are exceptions for less
than 1001 pounds of non-bulk containers of Table 2 materials:
Section 172.504(c) Exception for less than 454 kg (1,001 pounds):
“Except for bulk packagings and hazardous materials subject to §172.505,
when hazardous materials covered by table 2 of this section are transported
by highway or rail, placards are not required on a transport vehicle or freight
container which contains less than 454 kg (1001 pounds) aggregate gross weight
of hazardous materials covered by table 2 of paragraph (e) of this section…”
Again, at the risk of repeating myself, as a rule, any bulk and non-bulk Table 1 hazardous materials when
loaded into a truck will require the truck to be placarded. Table 1 materials are the more dangerous hazardous materials the amount or the type of container does not matter. However, Table 2 hazardous materials
are considered to be less dangerous, as long as they are in non-bulk containers.
So under this exception, if a driver picked up a single drum of Acetone, well
under 1001 pounds, which is only a Class 3 Flammable liquid in Table 2,
the drum would require the UN identification number marking “UN1090”,
the shipping name “Acetone” and a single 4X4 inch Flammable liquid
Class 3 label. And if the drum of Acetone was the only hazardous
material on the truck, then the driver would not be required to display
any placards on the vehicle.
What I find is that most shippers and carriers when taking this Table 2
non-bulk exception, miss the statement “aggregate total gross weight”.
Let me explain. If a shipper loads a single Table 2 bulk IBC container or
tote of a Class 8 Corrosive material onto the back of a truck, the driver
would display the 4 placards (with the UN number because of the bulk marking
requirement in 172.302) on each side and end of the truck. Again, this one bulk Table 2
material would require 4 Corrosive Placards, with their ID numbers on the truck.
Quite simply, one material on a truck, containing only an
IBC of corrosives would make it easy. But what surprises
most people is that if the driver of the truck were to
pick up a 55 gallon drum of a Class 3 flammable liquid,
which is also a Table 2 material, the truck would still
only require 4 placards on the truck because under
172.504(c) the aggregate total gross weight does
not apply to the bulk container. Some shippers and
carriers don’t know that you would only have to placard
the truck for the bulk IBC of corrosive, but not the drum
of flammable liquid because the amount of the non-bulk Table 2
flammable liquid on the truck has not exceeded 1001 pounds.
However, if this driver were to pick up, an additional four 55 gallon drums of a Division 6.1 poison (oral), a
flammable liquid on the truck has not exceeded 1001 pounds.
However, if this driver were to pick up, an additional four 55 gallon drums of a Division 6.1 poison (oral), a
different non-bulk Table 2 material, now because the Table 2 non-bulk containers on the truck have exceeded 1001 pounds, the truck would require a total of 12 placards. That would be 4 placards for the bulk corrosives IBC (with UN Number), 4 flammable placards, and 4 poison (oral) placards for the non-bulk containers (without their UN ID numbers). This means the driver must display 12 placards on his truck.
I know this does not make sense at first glance, since most trucks carry only one or two placard holders on
each side of their trucks. That’s because of 172.504(b), the domestic Dangerous placard exception. The
Dangerous placard may be used when a carrier loads
two or more Table 2 non-bulk hazardous materials that
require separate placards into one vehicle.
DOT states under 172.504(b) Dangerous placard:
“A freight container, unit load device, transport vehicle,
or rail car which contains non-bulk packages with two
or more categories of hazardous materials that require
different placards specified in table 2 of paragraph (e) of this section may be placarded with a
DANGEROUS placard instead of the separate placarding specified for each of the materials in
table 2 of paragraph (e) of this section.”
So, as I stated above, a shipment of one Class 8 corrosive IBC (bulk container), a 55 gallon drum (nonbulk) of Class 3 flammable liquids and the additional 4 drums of a Division 6.1 oral poison would still require
the truck to be placarded with 4 corrosive placards (with the ID numbers displayed inside) for the bulk IBC.
But the driver could substitute the Dangerous placard in place of the Class 3 Flammable liquid and the
Division 6.1 oral poison placards.
By taking the 172.504(c) exception, the driver could placard
all three materials using two types of placards. Corrosive
placards for the bulk corrosive totes, with ID numbers and
the Dangerous placards for the non-bulk Class 3 flammable
liquid and Division 6.1, oral poison materials, because the
truck contains an aggregate gross weight of hazardous
materials over 1001 pounds of Table 2 non-bulk containers.
And, of course, this could all fall apart if all the containers inside
the truck are not consigned to one consignor. In the case of the
driver unloading the one non-bulk Class 3 flammable liquid
container off the truck at his first stop, I believe at this point,
the Dangerous placard would no longer suffice. The truck
would require four Division 6.1 (oral) Table 2 Toxic placards
to be displayed in place of the Dangerous placards,
alongside the Corrosive placard (with the UN Number)
for the bulk IBC containers still inside the truck.
That’s not the only thing carriers must remember about the Dangerous placard, as they go about their deliveries, because 172.504(b) has the gall to further state: “However, when 1,000 kg (2,205 pounds) aggregate
gross weight or more of one category of material is loaded therein at one loading facility on a freight container, unit load device, transport vehicle, or rail car, the placard specified in table 2 of paragraph
(e) of this section for that category must be applied.”
That’s the rub; if the driver, in the course of his pick-ups
were to add a 55 gallon drum of Class 3 flammable
liquid from his first stop to his last, regardless of how
tainer, unit load device, transport vehicle, or rail car, the placard specified in table 2 of paragraph
(e) of this section for that category must be applied.”
That’s the rub; if the driver, in the course of his pick-ups
were to add a 55 gallon drum of Class 3 flammable
liquid from his first stop to his last, regardless of how
many pounds were on the truck, the Dangerous
placard would be applicable for the entire route.
However, if this same driver with the Class 8, Corrosive
placards for his bulk tote (with the UN numbers) and
Dangerous placards for his mixed load of non-bulk Table 2
Class 3, Flammable and Division 6.1 Toxic (oral), were to pick up seven additional 55 gallon drums
(over 2,448 pounds) of Class 3 Flammable liquid at one stop, the Dangerous placard would now
become moot. All three placards, the Corrosive, the Toxic and the Flammable would be required
to be displayed on all four sides of the truck.
Shippers love the Dangerous placard, carriers not so much. That’s because a shipper could offer the
driver the Dangerous placards for their mixed load of Table 2, non-bulk containers and then at the very
next stop, you unload a single non-bulk container or you load 1,000 kg (2,240 pounds) aggregate gross
weight, at one loading facility of Table 2 non-bulk containers, the driver might find the Dangerous
placard prohibited.
I would like to just mention one more thing. I don’t think some shippers and carriers (or even myself before I wrote this blog) were aware that the Dangerous placard is not only for mixed loads. The Dangerous
placard, believe it or not, can also be used when more than one placard is required to be displayed for one
material, but only in place of a Table 2 placard. DOT will allow the driver to use the Dangerous placard in
place of Table 2 placards when more than one placard is required under 172.505, for a single material. So
if you had a material subject to 172.505(a), where the non-bulk container’s Class 8 corrosive is the primary
hazard and the Division 6.1 poison Inhalation Hazard in Zone B is the materials subsidiary hazard, in one of
the few cases where the primary placard does not tell the shipper they are shipping a Division 6.1, poison
inhalation hazard, the Dangerous placard could be displayed in place of the one non-bulk material’s primary
Table 2 Corrosive placard.
Just remember, thIs material’s subsidiary hazard, the Division 6.1 poison inhalation hazard placard must
be displayed because of its Table 1 status; however, because the material’s primary hazard Class 8 corrosive placard appears in Table 2, the Dangerous placard could be displayed in place of the primary Class 8
corrosive placard.
Placarding is not easy, simple or even straightforward. And, of course, I did not even touch on the container or vehicle marking requirements in Subpart D, 172.300. And as with all of my blogs, this is only the way
that I see it, so if you see it differently, or you think I am giving inaccurate advice, please let me know. If
not, and you have questions please feel free to write or call. Thank you for your input, readership and
support.
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company, Inc.
Transportation Skills Programs, Inc.
©2017 Hazardous Materials Publishing Company, Inc.