Partial placards ?

Makes you wonder how some even got a hazmat certification.

 

Nope, packaging is different from the vehicle.

I am looking for the actual regulation that says you can’t have a partial placard on a truck or trailer, not a full one but a partial one.

 

Judging by the OP's post, i'd say a container.

 

Found it.

PLACARDING

General placarding requirements are contained in 49 CFR Subpart F Part 172. Each person who offers for transportation any hazardous materials subject to the HMR shall comply with the applicable placarding requirements. Applicability of placarding requirements 172.500: Placarding is not required for infectious substances, ORM-D, limited quantities, small quantity shipments, and combustible liquids in non-bulk packages. Placards may not be displayed on any packaging, freight container, unit load device, motor vehicle or rail car unless the placard represents a hazardous material loaded into or onto the conveyance unless the shipment is in accordance with the TDG Regulation, the IMDG Code or the UN Recommendations.

General placarding requirements are contained in 172.504. Each bulk packaging, freight container, unit load device, transport vehicle, or rail car containing any quantity of hazardous materials must be placarded on each side and each end with the placards specified in Tables 1 and 2.

 

Pump out a leaking rail tanker in a field in the dark and the PoPo don't care about placards...

AKA how do you take 4 rigs, a pickup and 6 people and make over $14,000.00 in one night.

And two days before the P & L closed, nice shot in the arm!

 

Problem is partial. How does DOT know it isn’t a hazmat load improperly labeled?

 

from this link …

Interpretation Response | PHMSA


Interpretation Response #07-0201

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details
Response Publish Date: 11-29-2007
Company Name: Q. A. Safety Individual Name: Mr. Ray L. Faucheux, Jr.
Location state: LA Country: US

View the Interpretation Document


Response text:
Nov 29, 2007



Mr. Ray L. Faucheux, Jr. Ref. No.: 07-0201
Security Manager
Q. A. Safety
5240 Coffee Drive
New Orleans. LA 70115

Dear Mr. Faucheux:

This responds to your letter dated October 15, 2007, regarding the term "obliterated" as it applies to placard displays on freight containers and transport vehicles under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You enclosed photographs of partial and painted over placard displays for our review.

According to your letter, your company"s coffee processing plant receives 20-foot shipping containers from all over the world. At times containers arrive at your company"s drop lots with placards, partial placards, painted over placards, and sometimes just the placard backing. Your questions are paraphrased and answered as follows:

Q1. Is it true that placards must be removed from a freight container and transport vehicle when it does not contain a hazardous material or after the containers have been cleaned?

A1. Your understanding is correct. Generally, no person may, by marking or otherwise (e.g., placarding), represent that a hazardous material is present in a package, container, motor vehicle, rail car, aircraft or vessel if the hazardous material is not present (§ 171.2(k)).

Specifically, no person may affix or display on a packaging, freight container, unit load device, motor vehicle or rail car a hazard warning placard unless the material being offered or transported is a hazardous material, the placard represents the hazard of the material, and the placard conforms to the requirements of the HMR (§ 172.502(a)(1)).

Placards on an empty packaging sufficiently cleaned of residue and purged of vapors to remove any potential hazard must be removed, obliterated, or securely covered in transportation (§§ 173.29(b)(1) and (2) and 172.514(b)(1)).

Q2. As the term "obliterated" is used under the HMR, at what point is a container considered not placarded?

A2. The term "obliterated", although not specifically defined under the HMR, is intended to mean destroy or eradicate (e.g., by painting over) so as not to represent that the container holds a hazardous material in transportation; at which point, a container is not considered placarded.

Q3. Is it permissible to paint over a placard, or partially remove it?

A3. Painting over the placard, if it completely covers it, would be acceptable; however, a partially removed placard display does not conform to the requirements of the HMR and is prohibited under § 172.502(a)(2)).

Q4. Is it permissible to have the glue or backing of a placard left on a container?

A4. The glue or backing of a placard left on a container is not a violation of the HMR.

The HMR do not prescribe methods for cleaning the outside of a freight container or a transport vehicle.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.

Sincerely,



John A. Gale
Chief, Standards Development
Office of Hazardous Materials

Here is in detail …

https://www.phmsa.dot.gov/sites/phm...etations/Interpretation Files/2007/070201.pdf

 

And the next argument will be what color of paint is legal to cover up the Placard.