Can i not get a hazmat endorsement with a CDL permit?

One thing I have learned over the last few years is NEVER quote a rule or regulation until you have actually defined ALL the words in said regulation. Most of the rules in title 49 CFR have a section where definitions can be found. Then you need to examine all the exceptions and run the links to the various other regs linked. Then be careful to remember a carrier by their policy or by insurance policy can actually be tighter than the rules say.

 

One last point that was just pointed out to me by a friend. IF you are leaving a customer with any amount of a substance that is considered dangerous regardless of the amount not only do you have to display placards, but you have to also have paperwork as required by rule. If by some chance you are in a crash and can't assist the authorities when they see those placards they are going to start looking for paperwork. This is something the CVSA teaches its members.

 

I pulled acids in a bulk tanker. The RQ for the acids I pulled was any amount, IIRC.
But here's a page from the Feds
Lesson 5: Hazardous Materials Involvement - Bulk Packaging
Bulk packages must be placarded unless cleaned and purged. A gas tanker that is empty and has not been cleaned or purged must remain placarded. On cargo tanks, the Hazmat Materials ID Number may also be found on an orange panel adjacent to the placard.

 

I hate to sound like a broken record, and I am not trying to argue just for the sake of starting a debate. I am going to paste the words here.

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

The issue is part 171.8 the official definition of hazmat for part 171 is found there. IF you have a substance in a trailer and that substance has an RQ less than what is in the vehicle that substance is NO LONGER considered hazmat. I do know there are some exceptions to the placarding requirements for things like tankers. In all honesty, when I see the word hazmat I am expecting to see a substance being hauled that is greater than the RQ, or a substance that any amount is hazmat. This is actually what I was taught by the CVSA.

 

The Feds say on their web pages for tanker trailers that it requires placards until it is washed. I think you are discussing your experience and training with dry vans and a couple of us are telling you about our experience with liquid tanker trailers. Look under the tanker trailer diagram at the link below. That paragraph also is what the tanker companies are using in their driver training materials. The RQ for the acids I hauled were "any amount".
Lesson 5: Hazardous Materials Involvement - Bulk Packaging

 

No, with all due respect. I am talking about almost 15 hours of CVSA training in all aspects of part 171. This includes tankers as well as dry vans. I am going to ask a Virginia DOT cop I know later about the rules about placards as it relates to non-hazmat CDL holders yanking them if no RQ is in the tanker. That's if I don't forget it. I am slowly losing what mind I had at one time. Peace!

 

The Feds say on their diagram at Lesson 5: Hazardous Materials Involvement - Bulk Packaging
"Bulk packages must be placarded unless cleaned and purged"
The liquid tanker is a bulk package.

Loading vans/reefers/flatbeds you either have a pallet of material loaded or you do not. The pallet is either HM or it is not. The determination of HM does consider the material and the quantity, but you are trying to impose an impractical dry van idea onto trailer containers that carry and deliver trailer size quantities. What you say about the material AND the RQ is true, for example you can carry a 53 foot trailer full of Bic lighters with Bic fuel inside and may not trigger a HM placards because the fuel is not carried in bulk containers, or containers over a certain capacity/weight. But the people you are arguing with are discussing multi-thousand gallon bulk loads of products, most of which are loaded by weight, not gallons. How do you propose to know when the stainless steel trailer with something inside is at or below the RQ, especially if the RQ "ANY"?
The quantity of material inside is not apparent to anyone from the outside. Why do you suppose the liquid bulk portion of the industry is not teaching your understanding to their drivers?

If you consider a dry van with some amount of HM, lets say IBC totes a bulk container, once the last IBC tote of HM comes off the trailer then you can remove the placards on the trailer for that material. However, tankers are don't dry vans with discreet units of material. They are bulk containers. Even a 3,4,5 compartment trailer is 3,4,5 bulk containers. The Feds say bulk containers stay placarded until they are washed or purged. Back to the IBC totes being unloaded from a dry van, once the IBC totes come off the trailer the placards can/must be removed from the trailer, but the placards on the IBC totes must remain on the IBC totes until they are washed or purged. I'm not disputing HM does require the quantity consioderation of RQs. Once again the Feds say them self Bulk packages must be placarded unless cleaned and purged.

 

Apparently the Feds don't read the exception either.
Lesson 5: Hazardous Materials Involvement - Bulk Packaging
Bulk packages must be placarded unless cleaned and purged.

I agreed with you that there are cases where the amount of the material does not trigger the HM placard requirement. I am posting over and over the feds own words talking about the example I posted (tanker trailers) and which caused you to spring into talking about the dry van cases that seems to occupy your so. The Feds them self on their training material state what I have been saying and you just repeat "this one time at band camp ...example." No tanker driver you know or have seen work operates with your "remove placards when the quantity of product in the tanker trailer drops below the RQ amount. No bulk tanker company is training their drivers to remove placards from the trailer once the quantity of product drops below the RQ amount. How long do you think it would take for you to calculate the liquid quantity or weight of the product remaining inside a liquid trailer if it was partially loaded? Lets assume the trailer is perfectly level front/back and left/right.

 

In all honesty, we are discussing something that is almost never going to happen. I don't know of anybody that hauls tankers that do not have the X on their CDL. So they will be moving the tankers from shipper to customer and either back to shipper or back to a terminal. So in a way this discussion is pointless. I would find it interesting to know though if a driver w/o Hazmat can legally yank a tanker with no RQ in said tanker EVEN if placarded.

 

How do you propose to know the moment a trailer holds less than the RQ amount? And show the cop the link and the quote from that link
Bulk packages must be placarded unless cleaned and purged.