Class 9 placarding of bulk shipments

Hey all, just picked up a load of vinegar that’s declared on the bills of a RQ of UN3082.

I know that Class 9 does not require placards if shipping domestically. What’s tripping me up is that “however, bulk shipments must be marked with the appropriate ID…” 49 CFR 172.504(f)(9).

It’s 5500 gallons in a tank. 47K lbs. My gut says I need to put placards on it with the UN # (could do the orange tags too; it’s not the placard that matters, but that the ID number is on the tank). Haven’t contacted my company just yet to confirm this. Thought I’d get some clarification before reaching out (it’s after hours for the office anyway).

Thanks. I’m used to hauling alcohol lol. And my company never said anything about class 9 products in training.

 

I found in my paperwork a copy of the Special Permit Authorization DOT-SP 16198 for the shipper, which specifically exempts food-grade vinegar with less than 30% acetic acid from the hazmat regulations. This load is 20% acetic acid and is food-grade, so with the permit, it’s not hazmat. So no placarding (not that I had to) and no ID numbers needed on the tank.

Here’s the description of the permit: https://www.phmsa.dot.gov/hazmat/documents/offer/SP16198.pdf/2024125284/SP16198

Interestingly, I hauled a load of vinegar the other day, and had a copy of that permit in the bills. But the load was declared as vinegar so I never looked up the permit. This load was declared as UN3082, with a full description, and that made me nervous for a second. Huge regulatory fines suddenly bursted into my mind - “I better check this out before Mr. DOT Man puts me and my wallet in the slammer.”

Thanks for the help!

 

Thanks - I knew I didn’t have to placard it. But I was confused on whether I had to put the UN number on the tank, since it’s a bulk shipment, and as far as I understand the CFR, bulk shipments of Class 9 require the UN or ID number on the packaging.

I learned after looking up the Special Permit DOT-SP 16198 that this load of vinegar is exempt from the hazmat regulations. The permit exempts food-grade vinegar with less than 30% acetic acid from the hazmat regulations. This load is food-grade and 20% acetic acid. So, we’re good to roll!

Always fun trying to understand what the government says is legal or not with this stuff lol. Feels like for every rule in the book there’s a dozen “yeah-buts” that’ll send you and your wallet packing if the DOT catches up to ya