hazmat placard rule

The rules for hazardous materials are clear and unwavering. The placards remain on the transport vehicle until there is no longer a placardable amount of hazardous materials on the transport vehicle......PERIOD! These rules have nothing to do with accidents on, or off public property.

As an example, a national chemical company at their world headquarters in Midland Michigan used to do just as you are suggesting, that is, removing the placards off trailers and railroad cars on their private property while still loaded. There were 4 of us that day about 17 or 18 years ago (at that time there were about 64 of us nationwide and traveled quite extensively) that were inspecting the plant and corporate offices (as federal DOT officers we legally inspected not only railroads, airlines, river barges, motor carriers and their driver's, but consignors (shippers) and consignees (receivers) of hazardous materials as well). After our inspection of their facility (which took almost 5 full days days because of its' size), we issued a civil penalty (fine) of over $225,000.00 just for the non-placarding of the transport vehicles (a simple definition of transport vehicle is anything used to transport hazardous materials). There were other fines as well but I show this one only to rebut your statement.

If the customer wants you to take the placards off before they're supposed to be removed you should tell them that it is not proper and/or legal to do so until there is no longer a placardable amount in your trailer. You and the consignee may both be held responsible, and both may be subsequently issued federal civil penalties if caught. Some state officers also have the same legal rights as we federal officials as well, depending on how that individual states laws are written (TX, NC, and OH come to mind immediately). It would more than likely be issued to you first because under the hazardous materials rules you are responsible for the contents of the transport vehicle (trailer) until it has been unloaded. I would also suggest that this consignee does not know the rules very well if they ask you to remove the placards before backing into their dock. I would suggest that they, and you read 49 C.F.R. parts 172.500 through 172.560.

I can therefore assure you sir, that "THE DOT" does care what happens on private property because the hazard still exists in that trailer until the hazard has been removed. Federal officials would not only inspect you on private property, but the warehouse as well. That is not only DOT rules, but OSHA rules as well.

 

It's all common sense here. I'd hate to think of all the liabilities that would be place on the driver if someone got hurt because they had no idea that the trailer was loaded with hazmat. It's very simple if it's there you have to communicate that it's there. No matter where the trailer is or where it's parked. If anyone tells you different they're wrong.

 

WoW, just...WoW. I know about the OSHA rules, and understand your background so I definitely won't argue against what your saying. Frankly, I had no idea DOT's authority was so wide-spread that they had authority over ALL types of transportation vehicles no matter where that vehicle happens to be; although, it goes to figure given the name. My experience with DOT has been very limited and I hope to keep it that way.

I do have a question about your other post though. Do the amount requirements pertain to tankers as well?

We spend half our time dead-heading back from our consignee's location. So is it correct under the quatity requirements that we can remove our placards after we are unloaded and run through tunnels and non-hazmat routes on the way home with a contaminated trailer as long as it doesn't meet the quantity requirements for placarding?

I have always left mine on and took the same route back with the understanding that I need to communicate the threat...also, what about driving to pickup a load with a recycled trailer that is also contaminated...and your paperword is the most recently used BOL with RECYCLED stamped on it?

 

As a general rule, there is still at lease a 2% outage/residue left in liquid bulk. This generally requires placards, but could differ depending on the material. You must also remember that I've been retired for a few years & the rules could have changed. Check the 172 and 397 rules for confirmation.

You should see the railroad rules. Once a tank car is unloaded and all that is left is the residue, the placard must be reversed. On the reverse side of a railroad placard it has the word "residue" on it & it must remain that way until reloaded, or cleaned & purged.

What is your definition of "pickup load with a recycled trailer"? Does this mean another trailer that means loaded?

 

lol - railroad rules - like the Oxford Unabriged Dictionary!

Bones - even leaving aside DOT )you pick the flavor(, you have to consider accidents.. and what if there's a fire? Or if you are in the midwest and a tornado blows through? The idea is for ANY emergency response to know what's in that trailer, and whether or not they have to worry about it.

I worked Urban Search and Rescue for a number of years... there were times where we were working in local light industrial areas, and knowing what was in those trailers was *essential*.

You do know one of the firefighters most feared fires, don't you? LTL trucks such as UPS - because they can have so much stuff on board that doesn't need placarding - multiple shipments of various chemicals - but under the placard limit. They have to treat every LTL fire as though the trailer were full of the nastiest stuff they can imagine (unless they can get to the manifest)

 

We as volunteer fires treat all truck fires this way. You never know what is there.

 

smart move. That's how I'd do it to (which makes a smart move, of course) I know agencies that don't though. Saw one agency just run up, pop the doors and start shooting water. No OBA (or whatever y'all call 'em these days), just regular turn outs.

My team leader tried to make a suggestion to the captain but was.. um... rebuffed. After that, we stayed WELL upwind.

Sure, nothing came of it, but that's hardly the point. And, as far as I know, policy at that agency hasn't changed.

 

DUMB! What if it was magnesium? Water increases that fire.

 

There is nothing in the rules or laws pertaining to docks, extensions of docks and the removal once the dock is bumped. The rule is that freight requiring a placard must have the four sides placarded until the freight is removed to its destination. Remove placards when empty, not partially empty or arrived at consignee, empty.
In my previous life I was an operator/firefight/medic, when responding to any incident involving HM, its always good to have some visual information as we are arriving at the scene. It justifies the elevated response which can be reduced to lesser level once all information is acquired.
Common sense says to remove the placards AFTER you are empty. Besides, the fourth placard on the rear door is easier to get to when the door isn't secured to the trailer wall.

 

In response to your sarcastic reparte', to someone who seems to have at least looked up the issue in the HM guidebook. I can only go by what is the law in (hold ur ears now) CA. Regarding fuel tankers and rail cars, the placards remain even after delivering to the fuel station, residue is the reason.
We all know that gas as a liquid is not the volitile point, its the vapors ( my grandmother had those a lot I was told). So a tank is never nonplacarded until decontaminated and properly dried.