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30 | 07 | 2010
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General hazmat placarding requirements

What requires a hazmat load to have placards? What are the DOT placarding requirements?  Do I have to placard for secondary (or subsidiary) hazards? What does table 1 and table 2 mean and how do those tables affect placarding? When can I use a 'Dangerous' placard? These are just some of the questions drivers ask everyday.

Making sure you are in compliance with placarding requirements is important. Putting on the wrong placards or not applying enough placards can get you placed out of service. Besides communicating the hazard, placarding requirements determine other compliance issues such as requiring a hazmat endorsement on a CDL for the hazmat load being carried, or extra permits that need to be inside the truck while the hazmat is being delivered.

 

When hazmat placards are NOT required

Let's start off by determining when placarding is not required. You will need to refer to your shipping papers to find out if any of these exemptions apply. These exceptions are found at the beginning of the placarding section in 172.500(b) and few other sections listed here.

Infectious substances: Ex. Regulated medical waste

ORM-D: Ex. Charcoal briquettes, some ammunition

Limited quantities: HM offered for transportation as Limited Quantities when identified on the shipping papers. Examples are "Potassium Bromate, 5.1, UN1484, II, LTD QTY"

Small quantities: As defined in 173.13 and 173.4 and packaged under those requirements. An once of sulfuric acid, for example.

Combustible liquids in Non-Bulk packages: Definition of Bulk and Non-bulk can be found on our hazmat basics page and in 171.8 in the regs. An example would be a one gallon can of paint thinner.

Class 9 materials in domestic transportation (172.504(f)(9))

Wet Batteries (see 173.159)

Materials of trade (173.6)

Some Cryogenic exemptions (173.320)

 

Table 1 materials - Placard any amount

Table 1 commodities, Bulk packages and Subsidiary placards that are one of 'The Big 3' (see below) will require that you must apply placards. The table below is taken from 172.504(e) which is broken down into 3 basic columns.

 

Here's a quick rundown of how its laid out:

Column 1 is the Category of the material, the hazard class and division. This number is found on your shipping papers, and also at the bottom of the placard. Since placards are shaped like a baseball diamond, this is the number at "home plate".

Column 2 Placards all have a name that's given in the section reference column, that helps to know which placard you're dealing with. The name of the placard is important. For example, a division 2.3 placard that has "Inhalation Hazard" (like the graphic at the top of page) is NOT called an 'Inhalation Hazard' placard...It's real name is 'Poison Gas'.

Column 3 is the section reference in the regulations that shows a picture of how the placard should look, and lists the name of the placard given in column 2.

Category of material (hazard
class or division number and
additional description,
as appropriate

PLACARD NAME
Placard design section reference
1.1
EXPLOSIVES 1.1
172.522
1.2
EXPLOSIVES 1.2
172.522
1.3
EXPLOSIVES 1.3
172.522
2.3
POISON GAS
172.540
4.3
DANGEROUS WHEN WET
172.548
5.2 (organic peroxide, Type B,
liquid or solid, temperature controlled

ORGANIC PEROXIDE

172.552
6.1 (material poisonous by inhalation, see 171.8 of this subchapter)
POISON INHALATION HAZARD
172.555
7 (Radioactive Yellow III label only)
RADIOACTIVE
172.556

1. RADIOACTIVE placard also required for exclusive use shipments of low specific activity material and surface contaminated objects transported in accordance with 173.427(b)(4) and (5)
or (c) of this sub-chapter.

View the gallery of table 1 placard pictures

 

 

Bulk Package placards

Bulk packages are required to be placarded. Here's the definition (paraphrased) of Bulk a package, which is defined in 171.8 as:

...a packaging other than a vessel or barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment and which has:

Maximum capacity of greater than 450L (119 gallons) as a receptacle for liquids, or

Maximum net mass greater than 400kg (882 pounds) and a maximum capacity greater than 450L (119 gallons) as a receptacle for a solid, or

A water capacity greater than 454kg (1000 pounds) as a receptacle for gas.

 

Subsidiary placards

'Subsidiary' for placarding purposes, essentially means 'Secondary' or 'hazard in addition to'. If the shipping papers are prepared in compliance with the regulations, any subsidiary hazards should be listed right after the primary hazard in parentheses for example, 3 (8, 5.1). Subsidiary hazards are listed under "column 6 - Label codes" on the 172.101 hazmat table.

The big question always is - "Do I have to placard for all subsidiary hazards"? The answer is NO. You only have to apply subsidiary placards for three types of material, one of which commodity specific. These placards are commonly referred to as the "The big 3". For many drivers and carriers, this is really the 'big 2'. Hazards other than the big 3 may be placarded for permissively.

 

Remember...

Once you have to placard for the subsidiary hazard, you must placard for the primary hazard, reguardless of amount your hauling. In other words, it's treated like its a table 1 product. For example, a material has a primary hazard class of 3 and a subsidiary hazard class of 6.1 poisonous by inhalation, one of our subsidiary hazards. The class 3 is a table 2 material that requires a 1,001lbs before it requires placards (scroll down to read more about table 2), so let's say we're hauling a 100lbs of it.

Because the subsidiary hazard is a 6.1 poisonous by inhalation, the transport vehicle must have two placards; A class 3 flammable placard and a 6.1 inhalation hazard placard.

The Subsidiary placards are:

Poisonous by inhalation 2.3 Poison Gas placard (172.540) and the 6.1 Poison Inhalation Hazard placard (172.172.55). Note these materials are also Table 1 materials. (172.101 table special provisions column 7, numbers 1-6 and 13

Dangerous when wet (Division 4.3)

Corrosive for Uranium Hexafluoride Class 7 - This very specialized, there will be no doubt you have this on board! This is NOT for EVERY corrosive subsidiary hazard. It's commodity specific, so it's ONLY for Uranium Hexafluoride.

View the gallery of subsidiary placards

 

Table 2 materials - 1,001lbs or more

Table 2 commodities require that you have 1,001 pounds (or more) of aggregate gross weight on-board before you have to apply placards. So the next question is: "What's aggregate gross weight"?

First, we'll start by defining what gross weight is, which can be found in 171.8 of the regs. Gross weight is simply the package (box, paint can etc.) plus the hazmat it contains. Package + contents = Gross weight.

Aggregate means that we're going to add the gross weight of all of those packages together to determine placarding. So if you're carrying 12 boxes of a class 3 flammable material that each weigh 100 pounds each, the total is 1200 pounds. You would have to placard for that hazmat, because the aggregate gross weight of the load is more than 1,001 pounds.

Table 2: 1,001 pounds or more

Category of material (Hazard class or division number and additional description,
as appropriate)
Placard Name
Placard design section
reference
1.4
EXPLOSIVES 1.4
172.523
1.5
EXPLOSIVES 1.5
172.524
1.6
EXPLOSIVES 1.6
172.525
2.1
FLAMMABLE GAS
172.532
2.2
NON-FLAMMABLE GAS
172.528
3
FLAMMABLE
172.542
COMBUSTABLE LIQUID
COMBUSTIBLE
172.544
4.1
FLAMMABLE SOLID
172.546
4.2
SPONTANEOUSLY
COMBUSTIBLE
172.547
5.1
OXIDIZER
172.550
5.2 ( Other than organic peroxide, Type B, liquid or solid, temperature controlled)
ORGANIC PEROXIDE
172.552
6.1 (other than material poisonous by inhalation)
POISON
172.554
6.2
(NONE)

8
CORROSIVE
172.568
9
CLASS 9 (see 172.504(f)(9))
172.560
ORM-D
(NONE)

 

View the gallery of table 2 placards

 

 

The Dangerous PlacardDangerous placard

This is the one placard that causes grief for drivers, carriers and officers and is probably the most misused and misunderstood placard of the bunch! Remember that it's an option not a requirement to use this placard. Required placards are those listed in Table 1 and Table 2. The Dangerous placard is not all that complicated to use if you follow the basic rules summarized below and listed in 172.504(b) of the hazmat regulations.

Here's the basic rules

1. You must have two or more Table 2 materials on board. This placard can NOT to be used for Table 1 materials

2. The packages have to be Non-bulk only

3. The 2,205 pound rule - As soon as you load 2,205 pounds of one class of hazmat at one facility you must placard for that material

Here are some examples

Ex. # 1: You load 600lbs of a class 3 (flammable) at one dock then drive to another dock and load 600lbs of a class 8 (corrosive). The total amount is 1200lbs, neither of which exceeded 2,205lbs at one facility. You could use a Dangerous placard for both materials.

Ex. # 2: You load 600lbs of class 3 at one facility and 3000lbs of a class 8 at a second facility. Now you must placard for the class 8 (corrosive). You could still use a Dangerous placard to cover the class 3 (flammable) because that shipment met all of the requirements.

 

Placard display requirements

There are general requirements on how placards have to be displayed in 172.504(a) and 172.519 of the hazmat regulations. Listed here are the basic display rules for placards:

Visible from the direction it faces

All 4 sides of transport vehicle

Securely attached (no peeling, flapping in the breeze)

Location: Clear of such things as ladders, pipes, doors, tarps etc.

Also must be located away from advertising that can reduce its effectiveness

Maintained so that color and visibility aren't reduced by damage, deterioration or obscured

Be on a contrasting background/color

Front placard can be on power unit or front of trailer, either one

Keep in mind also that you are not allowed to have "Drive Safely" placards (172.502) on your vehicle! If you're not transporting any hazardous material, make sure your placards aren't flipped open. You may also want to pay close attention on your pre-trip inspection and make sure there are no leftover stick on placards on your trailer also.

Also be aware that additional exceptions and substitutions for certain placards are provided for in 172.504(f) 1 through 11. You may want to check this section to insure that you have the right placards, or placard substitutions you may be eligible for.

 

UN four digit ID numbers on placards

un ID numbers on placards

By definition the U.N. identification numbers (ID) displayed on some placards are Markings and actually not considered part of the placard. The requirements for ID numbers are in 172.334, which outlines the display requirements. There are specific placards that can't have ID numbers on them. They are:

Radioactive placard

Explosive placards 1.1, 1.2, 1.3, 1.4, 1.5 or 1.6

Dangerous placard

Subsidiary placards

 

Quick placarding review

Here's a quick review on placarding. Remember that you should use your shipping papers and a DOT chart 13 (formerly the DOT chart 12) to check your placarding compliance.

When you MUST placard

Table 1 materials.

Bulk packages.

If the subsidiary hazard is one of the big 3, you must placard for the primary hazard.

All other placarding requirements.

Table 2 - 1,001 pounds or more aggregate gross weight.

Dangerous placards: 2 or more table 2 materials, Non-bulk only, Not more than 2,205 pounds loaded at one facility.

Exceptions: Don't forget to check for other exceptions in 172.504(f) 1 through 11.

 

Hopefully you found this section on general placarding helpful. If you have the time, read the article "Hazmat placarding on the fly for drivers - how to make your DOT chart 13 and shipping papers work for you".  Stay safe out there.

 

 
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