placard questions

It's the weight of the product you're carrying... over 1000 kg (2205 pounds) is considered a "bulk quantity" and you have to display the UN number in that case. Under that amount, and just the generic placard indicating the hazmat class is all you need.

 

it's actually the size of the package or container the stuff is in. a bunch of small containers is not bulk. bulk containers are generally bigger than a 55 gallon drum. bulk containers are the ones that require a specific number on the placard.

 

Pages 38-39 of the Hazmat Compliance pocketbook has the info you need. Bulk are tanks and must have the UN number on the placard. Non bulk requires no UN number on placards. I would read that book, it has lots of good info. Don't worry too much about the packaging since that shouldn't concern you and it gets really technical.

 

The haz mat rules in part 172 and 173 state that the UN/NA (North American) number need not be displayed until the weight of just the haz mat (not the weight of the haz mat plus the container) is 8,820 or more pounds in non-bulk (non-bulk is transported in containers inside a dry van trailer....bulk is like a tanker).

Shippers usually figure in the weight of the container when determining weight of haz mat which is incorrect, but permissive. I personally agree with this because too many state inspectors would write citations on things like gasses in this regard because of being trained improperly. In any event, nowhere in the rules is the container required to be included in any haz mat weight with the exception of the tare weight when completing the bills of lading.

In any event, and if required, they need not be displayed in the middle of the placard. They may be displayed on an orange panel. The middle of the placard is the option but is used more often because of it's simplicity, as well as cost (a placard plus an orange panel costs more than a tag board placard printed with the number).

From the old retired federal DOT haz mat specialist

 

There's no doubt it had to have a placard because your load was more than1001 lbs. The requirements are listed in the CFR49 100 to 177 at
§172.504 (c) and is always determined by weight. so you needed a placard because you were over 1001lbs.

What I think they did was they looked at Hazardous Materials Compliance pocketbook Hazmat Table too fast and did not see the right requirement for hydrochoric acid. There's a reference in the table that refers you to anothing reference that does not match. So they could have used that example which requires no ID numbers. Other than that everyone screwed up here and didn't check the proper shipping name with the table to see what was required.

If the proper shipping name was "Hydrochoric acid" then you should have had placards marked corrosive UN1789 Class 8 pg2. But you know as a driver you are required to check that yourself. You should have crossed referenced it with the shipping papers and the Hazmat book. If it doesn't match then you reject it or stop the load and have them fix it. They have to provide you with all the paperwork and placards that is required for the object they are offering you.

 

I still don't see that 8820 lb. reg in the pocketbook. Managed to find it online though. Thanks for the clarification.

 

When you say "pocketbook"; are you referring to the orange Emergency Response Guidebook (ERG)"? If so that book is inapplicable. It is only a mini Material Safety Data Sheet (MSDS) guide and has nothing to do with the rules. If your talking about one of those guides to haz mat transportation you must remember that it is nothing but a condensed variation to the actual rules, and should not be considered as anything close to the rules.

 

Its the JJ Keller Hazmat Compliance Pocketbook. Ya I'm finding out that I can't rely solely on it.

 

Those little green J.J. Keller books with the rules are about 1/2 the size of the book containing the haz mat rules, The motor carrier rules (49 CFR 300 to 399) book is about 540 +/- pages & the haz mat book is over 900, or at least it was before I retired,