Liquid Totes And Tanker Endorsement

I saw a whole bunch of random broker websites with articles claiming it's required and that they know what the rule is, but is there any FMCSA guidance that defines attachment as a load inside a trailer?

 

Forget the semantics regarding a tank attached to the vehicle. This has been defined already that the rule applies to totes in van trailers. The containers have to have a capacity of 119 gallons or more, and the total amount of liquid carried has to be 1,000 gallons or more in order to require the endorsement.

Since most typical totes have a capacity of 275 gallons, 4 full totes would trigger the legal requirement for the endorsement. A shipper can require every driver to have the endorsement if they choose, but the law doesn't care until the liquid load reaches 1,000 gallons. And 55-gallon drums don't count. Only containers of 119 gallon capacity or greater.

 

Wait, are you saying 55-gallon drums count?

 

So for 2000 gallons of vinegar in 55lbs drums, tanker endorsement is not needed?

 

Correct.

 

If I get an inspection, can I mention you as a reference?

 

The requirements is both >119 Gallon containers and >=1000 gallons total.

 

I have learned most places don't even check if you have a tanker just be careful not to get in a accident.

 

Then there's the opposite end of the spectrum. Some of our Hazmat customers don't have their act together.

For example, last month I am dispatched on a "Power Only" load to hook to a preloaded flatbed and haul it to a frack site.

I bobtail to the customer's yard at the appointed time and NOBODY is there, BUT the gate is WIDE OPEN. So I find my trailer, hook to it, then start securing the mixed load of totes and sacks with straps that should have been retired years ago. I start scavenging better straps from other trailers. Then I wander inside the building. Nobody is there. I find placards for the three UN numbers. No SDS sheets. I call dispatch and alert them to the situation. An hour later an employee shows up and doesn't know what an SDS sheet is. Another two hours to print out SDS sheets.

Any terrorist would have had an open door to some nasty ####. The yard was open, the offices were open, no security cameras,... Jeesh!