22 Spray August 2017
Steven CharleS hunt
President, ShipMate, Inc.
From here to there:
Topics in
Transportation
Placarding Requirements Explained
I am often asked whether placards are required for certain
consignments of dangerous goods or for particular modes of
transport, and whether or not the driver must “be certified.”
Many shippers (and, indeed, even carriers) are confused by the
placarding and driver Hazardous Material (HazMat) endorsement
requirements.
Placarding Requirements
Placards, or “enlarged labels” as they are referred to in the
International Maritime Dangerous Goods (IMDG) Code, are
warnings that are applied to the exterior visible surfaces of cargo
transport units (e.g., freight containers, tractor trailers, portable
tanks, rail tank cars) that communicate the hazards associated
with the dangerous goods contained within the cargo transport
unit.
a package (e.g., cylinder, box, drum or bag). “Marks” (such as the
fumigation warning, keep away from heat, cryogenic, elevated
temperature, marine pollutant) are symbols that communicate
specific requirements and are generally placed on the package;
however, some “enlarged” marks may also be applied to the
outside of cargo transport units (e.g., elevated temperature
material, marine pollutant); these are generally applied as
adhesive labels and located near the hazard warning labels, cargo
handling labels and other required markings.
Additionally, the term “markings,” generally refers to text
applied to the outside of a package or cargo transport unit, such
as the proper shipping name, identification number and U.S.
Dept of Transportation (DOT) Special Permit number.
The Title 49, Code of Federal Regulations, subchapter C, Part
172 includes the provisions for:
• Marking
Marking Subpart D
• Labeling
Labeling Subpart E
• Placarding
Placarding Subpart F
General Placarding Requirements
With respect to the placards applied to the exterior visible
surfaces of a cargo transport unit, placards are not required in the
following cases:
• Infectious Substances (Class 6.2)
• Consumer Commodities (ORM-D)
• Limited Quantities
• Excepted Quantities
• Combustible liquids in non-bulk packagings (where the
flashpoint is greater than 140°F but less than 200°F and the
volumetric capacity of the receptacle is 450L (119 gallons) or
less)
49 CFR Part 172, Subpart F requires that each
bulk packaging, freight container, unit load device,
Table 1 must be placarded for
Dangerous goods shown in
surface (road/rail) transport regardless of the amount of material
being carried in the cargo transport unit.
However, hazardous materials in
Table 2 are excepted from
placarding when transported in non-bulk packagings (where the
volumetric capacity of the receptacle is less than 450L for liquids,
400 kg for solids, 1,000 lbs water capacity for gases) and the
aggregate gross weight of the hazardous materials are 1,000 lbs
(454 kg) or less. This is referred to as the “thousand-pound rule.”
It also important to note that there are a number of exceptions
from placarding, which can be found in 49 CFR § 172.504(f). T\
Most notably, the provisions of 49 CFR §172.504(f)(9) state that:
Placards are not to be confused with “labels” which are
similar warnings that are applied to the outside surface of
the
• Packages transported in accordance with the
exceptions in 49 CFR § 173.13
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 Table 1
and Table 2 of section 172.504 and in accordance with other
placarding requirements found in that subpart.
CDL driver