Crude/rec oil/1993 in a vac w/ no placards & 1 butterfly valve?

so yeah here I am once again deeper in poo poo then I thought I was for trying to go out and learn crude transport and how to run a vac trailer to get the experience for possibly a better job but now it’s occurred to me that the reason why they've been so adamant to keep their vac trailers spotless.
the same place we’ve already run to once in the last two weeks where we ran an actual crude transporter with the proper 1993 placards and containment barriers/valves is basically out of service so now we’re literally running the vac truck down there to pick up the same load.
The only real resource I have for this is a thread from 2012, which references the CFR that basically says anything over 10% hazmat in the bulk your carrying is considered hazmat and should be treated as such.
I realize we have quite a few cowboys and outlaws around here and that the chances of getting tested or a literal roadside grind out or slim to none but for me, I don’t really care to take the chance and just want to get at least some up-to-date clarification on this.
I’ll put the previous thread below here and would cite/credit the user guntoters post


Can you haul Crude Oil on a Vacuum Trailer?

 

And just to clarify the pickups are from recovery facilities where the usual water content comes out at no more than 20% and the oil is around 50% or better. 140bbls total *\-.

 

Yeah it (the vacuum trailer) doesn’t have any VLKPUIC certs or placards for 1993 or 1267. The owner told me it wouldn’t be considered hazmat unless the flash was below 140 deg lol. I mean seriously, the tank only has two simple butterfly valves for the male/female outputs in the back and a flimsy PVC sight glass setup. I basically asked him wth does he think is gonna happen to me if someone rams into the rear end, hits one or both of those flimsy valves and I can’t stop the flow or the sludgey 40+% oil/water mix that is listed as production water/exempt on my BOL.

 

Had the talk and was told I would be put on the crude transporter since I “wasn’t ready for the vacuum truck”. Yesterday was a plant day where we only move clean/dirty product around the plant (with the vac) cause the piping around the tank farm isn’t set up to move from one yard to the other and the pumps they have in the yard just aren’t strong enough either.

Well, we were pulling in some serious thick sludgey junk for too long I guess add the vac pump burned up and seized so the pump is dead. Before we had run that pump maybe four or five hours straight and either mode and it ran fine, but I think this was just too much for it to pull.

I’d be lying If I didn’t leave the yard driving home, thinking in someway this had to be some sort of karma or someone up there looking out for me to keep me out of this truck for a little while longer .

Seriously appreciate everyone chiming in about this because it does seem now like I’m at a serious crossroads, trying to learn this business and with a kid on the way into this world in less than a week.