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Probably considered orm-D due to the small quantities of hazardous materials in the vehicles. Ive hauled hazardous chemicals before, but they were not in large enough quantities to be reportable. So they didn't need placards.

 

If it is ORM-D, the product is still labeled and the BOL states its class 9 or ORM-D. I've never seen a car hauler running down the highway with a ORM-D label attached to the freight, which is required. Also the BOL must state the product that is being shipped in limited quantity. I.e. (5) 10oz cans of engine LMTD QTY

 

Actually, automobile loads are considered haz-mat, but only for minimum public liability insurance requirements of the FMCSA. We car haulers are required to maintain the $1 million minimum liability instead of the general freight limit of $750,000. This is to help cover the increased costs of clean up after an accident involving a car hauler where fuel and other fluids in excess of what would be normal could be spilled. This is the actual regulation that requires us to carry the million dollar liability and the guidance explaining why is below. It is because the motor vehicles in transit contain oil, gasoline, diesel, and other fluids that do not meet the quantity requirements for placarding or haz-mat carrier licensing, but can be a hazard to the environment if spilled.
§387.9 Financial responsibility, minimum levels.
The minimum levels of financial responsibility referred to in §387.7 of this subpart are hereby prescribed as follows:

Schedule of Limits—Public Liability

Type of carriage Commodity transported January 1, 1985
(1) For-hire (In interstate or foreign commerce, with a gross vehicle weight rating of 10,001 or more pounds) Property (nonhazardous) $750,000
(2) For-hire and Private (In interstate, foreign, or intrastate commerce, with a gross vehicle weight rating of 10,001 or more pounds) Hazardous substances, as defined in 49 CFR 171.8, transported in cargo tanks, portable tanks, or hopper-type vehicles with capacities in excess of 3,500 water gallons; or in bulk Division 1.1, 1.2 and 1.3 materials. Division 2.3, Hazard Zone A, or Division 6.1, Packing Group I, Hazard Zone A material; in bulk Division 2.1 or 2.2; or highway route controlled quantities of a Class 7 material, as defined in 49 CFR 173.403 5,000,000
(3) For-hire and Private (In interstate or foreign commerce, in any quantity; or in intrastate commerce, in bulk only; with a gross vehicle weight rating of 10,001 or more pounds) Oil listed in 49 CFR 172.101; hazardous waste, hazardous materials, and hazardous substances defined in 49 CFR 171.8 and listed in 49 CFR 172.101, but not mentioned in (2) above or (4) below 1,000,000
(4) For-hire and Private (In interstate or foreign commerce, with a gross vehicle weight rating of less than 10,001 pounds) Any quantity of Division 1.1, 1.2, or 1.3 material; any quantity of a Division 2.3, Hazard Zone A, or Division 6.1, Packing Group I, Hazard Zone A material; or highway route controlled quantities of a Class 7 material as defined in 49 CFR 173.403 5,000,000
[73 FR 76946, Dec. 16, 2008]
Guidance for § 387.9: Financial responsibility, minimum levels.
Question 1: Is gasoline listed as a hazardous material, and, if so, what is the minimum level of financial responsibility currently required?

Guidance: Gasoline is a listed hazardous material in the table found at 49 CFR 172.101. §387.9 requires for-hire and private motor carriers transporting any quantity of oil in interstate or foreign commerce to have a minimum $1,000,000 of financial responsibility coverage. The Clean Water Act of 1973, as amended, declares that gasoline is an "oil," not a "hazardous substance." The $1,000,000 coverage also applies to for-hire and private mo tor carriers transporting gasoline "in-bulk" in intrastate commerce.

 

Here is the rest of the guidance I meant to post above.
Question 8: Are motor vehicles being transported considered to be HM for purposes of the financial responsibility requirements, thus requiring the higher limits set forth in the regulations?

Guidance: Yes. Even though vehicles being transported by motor vehicle are subject only to 49 CFR 173.220 of the Hazardous Materials Regulations (HMRs), they meet the definition of “Hazardous material” in 49 CFR 171.8 because “Vehicle, flammable gas powered” and “Vehicle, flammable liquid powered” are designated as hazardous in 49 CFR 172.101 [UN 3166]. For that reason, vehicles transporting other vehicles would have to carry $1,000,000 of public liability insurance.

 

Very interesting. You would think that since you have maybe 8 cars, 10-15 gallon fuel tank each, and equivalent 80-120 gallons of some highly flammable liquid on board in the freight area of the truck, that a hazmat placard should be displayed to alert potential bystanders of a danger. Should the cars catch fire, start leaking into a water way after a roll over.

 

As explained to me by a DOT officer, it is obvious to the public the cars have flammable fluids inside. Besides, please don't give the FMCSA any ideas! I don't need any more complications in my business LOL

 

I thought my left turn signal was an obvious alert I want to merge. Apparently not obvious enough...

 

It is 49 CFR 171.8 and 49 CFR 172.101, that declare UN3166 for vehicles, gasoline powered and vehicles, liquid powered. No hazmat endorsement is required, nor is registration as a hazmat carrier only the increased public liability of $1 million instead of the $750,000 general freight haulers need.