DOT Placarding – Here’s Your Sign!
We recently looked at the Federal Motor Carrier Safety Administration (FMCSA) 2016 Top 10 HazMat Violations related to transporting hazardous materials. Four of those top 10 violations that occurred during roadside inspections dealt with failure to use placards appropriately.
So, what do you really need to know about placarding requirements? The Pipeline and Hazardous Materials Safety Administration (PHMSA) offers some guidelines regarding placarding—what’s permissible, what’s prohibited and what’s problematic.
Think of a placard as a label, just for a larger package.
Labels are typically applied to packages or drums, and if hazardous material is held in the container, the label identifies the important information related to the hazard. A placard on a freight container or vehicle, such as a truck or railcar, is used to convey the same kind of information.
If the cargo being carried is hazardous, it is critical that the information on the outside of the vehicle be clear and easy to identify, so emergency personnel can safely and expeditiously respond to any incident.
Department of Transportation (DOT) placards require a uniform style and design so emergency responders don’t have to guess what might be inside a vehicle in the event of an emergency.
If a placard is obscured from view, not readily visible or identifiable, then the transporter is in violation.
According to the DOT placarding rules (49 CFR 172.502), “No person may affix or display on a packaging, freight container, unit load device, motor vehicle or rail car any sign, advertisement, slogan (such as “Drive Safely”), or device that, by its color, design, shape or content, could be confused with” a DOT placard.
What does this mean for trucking companies who use their transport vehicles to advertise their services or even offer ad space for rent as a way to earn extra income?
It’s important to recognize that even if the transport vehicle is not carrying hazardous materials, the operator must still be aware of DOT hazmat placarding rules so they can ensure no advertising or logo display on the vehicle could be confused with a hazmat placard.
Fortunately, the placement of DOT placards, as well as the layout and design of the hazard information, is standardized and readily available information. In fact, you can download a copy of the US DOT Pipeline and Hazardous Materials Safety Administrations Placarding Guide here:
Becoming familiar with DOT placarding rules is a necessary step for anyone in the transportation industry. Ensuring your hazmat transport vehicle conforms to the required placarding is equally as important as ensuring your non-hazardous load doesn’t display any markings that could be confused with a hazmat placard.
When is a Hazmat Placard NOT Required?
Are there instances when a hazardous material is being transported, but no placarding is required?
In the United States there is one hazmat class that does not require placarding. Class 9 hazmats are a group of miscellaneous hazardous materials that present a hazard during transportation but do not meet the definition of any other hazard class (e.g., oxidizers, flammable, corrosive). This class includes:
- Any material which has an anesthetic, noxious or other similar property that could cause extreme annoyance or discomfort to a flight crew member and prevent them from performing their assigned duties
- Any materialthat meets the definition in the Hazardous Materials Regulations (HMRs) for an elevated temperature material
- A hazardous substance, a hazardous waste, or a marine pollutant.
Even though a Class 9 placard does exist, it is not required for domestic transportation, including any international transportation that occurs within the United States. There is still a requirement for any bulk packaging of a Class 9 hazardous material to be marked with the appropriate identification number. This number can be displayed on the Class 9 placard, or on an orange panel or white diamond, which is not considered a placard even though the color and shape are similar. However, even if the Class 9 placard is used to display the identification number, the shipment will not be subject to the additional requirements that apply to other placarded hazmat shipments.
Have Questions or Need Help?
Questions or Need Help? Give us a call at (512) 301-1451 and we’ll be happy to assist in answering your questions.
Also, see our related Hazmat Transportation EHS Blog:
- HazMatShipping: It’s Time to Secure Your Load: http://thrivalschool.com/hazmat-shipping-violations
Additional Useful Links and Guidance
- Federal Motor Carrier Safety Administration website @https://www.fmcsa.dot.gov/regulations/hazardous-materials
- DOT &FMCSA Hazardous Materials Transportation Placarding FAQs@ http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c8789/?vgnextoid=8bd292dfcb0e8110VgnVCM1000001ecb7898RCRD&vgnextchannel=18557e2cd44d3110VgnVCM1000009ed07898RCRD