hazmat placard rule

Placards don't come off until trailer is empty

 

I am a retired federal DOT haz mat officer and can state without question that the placards are removed when there is not an amount of placardable material in the transport vehicle (trailer). This means that the trailer must remain placarded until all class 1 (explosives), class 6 (poisons), and Class 7 (radioactive) is removed from the trailer. With all other haz mat you legally remove the placards when the material in the trailer is less than 454 kg (1,001 lb.).

 

####, it's nice to have you on the board!

 

There is no such consideration of being an extension of a dock. The rule requires placards until there is no longer a placardable amount in the trailer (see my previous statement). The placarding rules are in part 172. I defy anyone to show me in the placarding rules anything about a dock, or an extension of a dock.

From the old retired federal DOT official

 

the more I think on that "Extension of the dock" thing, the more I think it's an insurance issue, and nothing at all to do with the load.

 

I havent been hauling hazmat that long but I know not to take the placards off untill the hazmat is off loaded. And no I'm not trying to be a smart a&*, it's just common sense.

 

FYI: The federal (not state) fine for not placarding assuming it is a civil penalty is up to $41,500.00 per violation per day (if 4 placards are missing it can be considered 4 violations). If it was caught for 4 straight days then that is 16 violations. 16 X $41,500.00 equals $664,000.00. This amount may have increased since I retired because of the cost-of-living standard that is figured into fines each year.

Criminal penalties for knowingly, and/or willfully violating can be up to $500,000.00 per violation per day and/or 5-years in a federal pen per violation per day.

States set their own amount for these violations.

These penalties/fines have absolutely nothing to do with an accident, death, or anything but a failure to placard.

Any you all know where I used to work

 

I also think I forgot to mention that Class 9 (Miscellaneous Hazardous Materials)need not be placarded in non-bulk (like many boxes in a dry van) while in the United States. Canada does have a placarding rule for Class 9 but there is also an agreement between the 2 countries that if it is transported & placarded correctly in it's country of origin then it's legal to it's original destination in the other country. But if the load is re-consigned to a different consignee/location en-route the the load must meet the rules of both countries.

The reciprocal rule that allows this is 171.12A.

Also, Canada does not recognize a Combustable placard but it is permissive under the reciprocal rule.

 

There is no such thing in the haz mat rules.............see 49 CFR part 172

 

Until the consignee signs for the load, you are responsible for that load...period. However, if you are on the customer's property and they want the placards off, backed up to the dock or not, I see no reason not to take them off.

The purpose of placards is for authorities to know the potential hazards involved if you are in an accident. Since you are not on the public roadways then DOT isn't really concerned here. Any accidents that take place on the customer's property is between you, them, and your safety department. Edit: In the case of a spill, however, you are required by law to report it...even if you are on company property.