This is probably one of the most thorough guides you’ll read on the net about hazmat placard regulations.
The best part?
This guide will give you 100% actionable info you can use today without fancy software or apps.
Is anything with DOT placards ever that simple?
That’s a definite maybe.
Hazmat placard regulations on the surface seem simple, but they’re not (I guess we have attorneys and lobbyists to thank for that). In this guide I will show you a way to check compliance without expensive software.
Apply the wrong placards, not enough of them or display them improperly, can potentially get you placed out of service. Of course if you’re placed out of service, it can cost you time or money, or both.
Besides communicating the hazard, hazmat placard regulations can determine other compliance issues such as requiring a hazmat endorsement on a CDL, permitting, or whether or not other DOT regulations get applied to you.
So grab a beverage and a snack, this is going to be a long read!
For basic placarding purposes, there are two key pieces of information that you need to know. “Basic placarding” means defaulting to the basic rules that were going to discuss later and exclude exceptions to placards (there are many).
If you use the basic rule correctly even if you’re not required to display placards, you can’t go wrong. Notice I said correctly.
Back to the two pieces of info. Every shipment contains two pieces of information (they’re required to be there by regulation) specifically for the purpose of determining placards.
These two pieces of information are the materials hazard class and/or division (if a division is appropriate) and the weight of the hazardous material. These two items are found on the shipping papers.
Take a look at this shipping paper:
In the picture, we see a shipping paper with two hazardous materials that are highlighted. We’ll take a look at the first entry, which is “Hypochlorite Solution” (a fancy term for bleach).
First, we need to find the materials hazard class, which appears after the hazmats proper shipping name. In this case, the materials hazard class is 8 (which is a corrosive).
If it’s hard to see, the 8 is right after the word “solution” in the proper shipping name “Hypochlorite Solution”.
If you don’t know what a hazard class is, no worries we’ll go over it in the next section.
Next, we need to know how much the hazardous material weighs and what kind of packaging it’s in. This will tell us whether the hazmat is considered bulk or non bulk. That’s important to know, because different rules apply to each.
So for our Hypochlorite Solution entry, we have 600lbs, spread over several packages.
Now we have our two pieces of information that we need to determine dot placarding;
Hazard class 8 and a weight of 600lbs.
We’ll deal with that other entry later. See if you can pick out the hazard class and weight yourself.
So let’s see what a hazard class and division is.
If you’re familiar with placards (which means you probably already have your endorsement) or you’re just starting to learn about them, let’s go back to the basics to help you get started. The hazard class is also the number you see at the bottom or “home plate” of the placard.
There are 9 hazard classes/divisions. A hazard class is a category of a hazardous material and a division is a sub category of a hazmat hazard class. As you’ll see in the picture, not all hazardous materials have a division associated with them.
Hazard classes 1, 2, 4, 5 and 6 all have sub categories or divisions (meaning they’re further divided)
Flammable materials have a hazard class of 3 – There is no further division.
Explosives are further broken down into divisions because of their many types –
1.1, 1.2, 1.3, 1.4, 1.5, and 1.6
Look at the table and you can see how explosives are further divided down.
Gases (hazard class 2) are divided into 3 divisions: Flammable gas, non-flammable compressed gas and poison gas
See how it works?
Here’s a table that shows all of the hazard classes and divisions.
ORM-D is not considered by many to be a hazard class, but it’s listed so we’ll run with it. It’s worth noting also, that the ORM-D designation is being phased out.
It’s good to get acquainted with hazard classes and divisions, you’ll see them all over the place when it comes to dot hazmat compliance. They’re on shipping papers, placards, labels just to name a few places.
Also, get familiar with the names for each hazard class. It’s helpful to know that hazard class 3 refers to materials that are flammable or that hazard class 2 refers to materials that are gases.
If for any other reason, so that you know what’s parked next to you or what you’re parking next to.
Might need to reconsider parking right next to someone that’s hauling poison gas. Just sayin’.
If you haul one hazard class the most, chances are you’re familiar with what you’re dealing with.
I said in the beginning you needed to two pieces of information on your shipping papers and we’ve just covered the first one: Hazard class.
Now let’s take a look at the second piece of information: Weight and package type
Again, which placarding rules you apply will depend on how much weight and kind of packaging the hazardous material is in.
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In hazmat, the size of the package matters.
Whether or not the hazmat package is bulk or non bulk will make a difference as to how many regulations will apply to it. This becomes important for placarding hazardous materials as we’ll see later on in this guide.
So how do you know if things are bulk or non bulk? It depends on the capacity of the container or packaging the hazardous material is in.
More than a 119 gallons for a liquid.
Greater than 882lbs solid.
Water capacity greater than 1,000lbs as a receptacle for gas.
Non bulk hazmat is obviously going to be less than the figures I just gave you. In my article bulk vs non bulk I give you the figures right out of DOT hazmat regulations, check it out. No really, you need to read it, go there right now then come back.
Placards are broken into two groups or “tables’ as they are referred to in the DOT regulations, by their hazard class. Let’s take a look at those.
At its core, the dot hazmat placard regulations are pretty simple. The hazmat regulations break placards into two distinct groups each with their own requirements:
Table 1 Placards: Placard for any amount
Table 2 placards: Placard for 1,001lbs or more of aggregate gross weight.
Next, we're going to break down each one of these tables.
Table 1 placards represent the major bad boys of hazardous materials world and are generally items that have been referred to as the “kill you now” materials, such explosives or poison gas. Table 1 hazard classes/divisions are listed as follows:
Explosives – 1.1, 1.2, 1.3
Gases – 2.3; poisonous by inhalation
Dangerous when wet – 4.3
Organic peroxide type B, liquid or solid, temperature controlled – 5.2
Materials poisonous by inhalation – 6.1; these are generally considered liquids or solids that are giving off fumes. Materials in hazard class/division 2.3 are in a gas form.
Radioactive 7; Not all radioactive materials require placards, only those materials that are required to be labeled “yellow III”.
Here’s a graphic of Table 1 materials:
Notice in the graphic that there are two columns. Column 1 tells you the category (hazard class or division if it applies) and any other information.
Column 2 tells you the name of the placard. Everyone has a name, and placards are no exception!
Why would knowing the name make a difference? Here’s why:
Look pretty much the same right?
A common mistake that driver and inspectors both make is calling these “Inhalation Hazard” placards. But according to the chart above, that would be incorrect.
When we look in the Category column for hazard class 2 we see that it is listed as 2.3 and its name is “Poison Gas”, not inhalation hazard.
The placard name for the 6 or 6.1 as it is listed is “Poison inhalation hazard”. Two different names, because the reality is, is that they are two different things – one is a gas, and the other is a liquid or solid that is giving off fumes.
So your question is “That’s stupid and why the in the hell do I care?”
Good question! I appreciate your frustration as well.
For starters, the phrase “Inhalation hazard” in not required to appear on the placard. Many times it’s on the placard to fulfill other DOT requirements.
Also, the name of the placard can occasionally determine what hazmat regulations apply to the load. Poisonous materials and foodstuffs come to mind, but that’s a story for another time young grasshopper! (extra points if you can name the tv show referenced)
Now for the magical question – “How much of a Table 1 material do I have to have before I must put placards on?”
This is the easy part –
If you are transporting any amount of a Table 1 hazardous material, you MUST put placards on the transport vehicle. It doesn’t matter if you have a small amount or 2000lbs, a million pounds (ok I’m getting crazy) onboard your vehicle… you must have placards. Did I say any amount yet?
It also doesn’t matter the size of a transport vehicle. If you are transporting a table 1 hazardous material in commerce on a bicycle, you must have placards on that bike. Hazmat placard regulations can be funny sometimes…
You’re going to need extra hazardous materials permits. In fact you will need at least one permit or two federal permits, depending on the load.
For quantities of certain Table 1 materials you may also need an FMCSA “Safety Permit” which may be in addition to any required state permits may need. Drivers, check with your company, companies check with the appropriate authorities in your state.
You may also need things such as a written route plan as well.
I said earlier that there were two tables, so let’s move on to Table 2. Table 2 placards is where most of the confusion comes in.
A consequence of that confusion can be a getting a ticket, placed out of service, both, CSA points and being forced to watch “Encino Man” starring Pauley Shore on a 24hr loop.
Ok, the Encino Man thing wasn’t true, but the stuff before it was. If you’ve never heard of Encino man the movie ignore ignore my bad joke.
Here is a graphic of Table 2 hazardous materials:
Now we’ll get into a bit of territory everyone has a general idea about. You have to placard for table 2 hazardous materials once you have 1,001 pounds of aggregate gross weight.
What is aggregate gross weight? It simply means that you add up the weight of all packages + contents and include that towards the 1,001 pounds.
Here’s an example:
Suppose you have 600 pounds of Corrosives (class 8) and 600 pounds of Flammable (class 3). You add these materials together and you get 1,200 pounds of aggregate gross weight. Your vehicle would then have to be placarded like this:
Each material is below the 1,001 pounds but together (in aggregate) they are over 1,001lbs, which means the load would require placarding.
Remember all that talk of bulk and non bulk?
DOT Rule: If the hazardous material is in a bulk package you MUST placard for it no matter what table it’s on. Unless there’s an exception – I’m looking at you hazard class 9.
One of the biggest mistakes that companies and drivers make is thinking that you need 1,001 pounds of each class before you put placards on for a specific hazardous material. This untrue (as you saw above) and you may be ticketed and placed out of service.
The word ‘subsidiary’ means secondary or subordinate. So a subsidiary hazard is a secondary hazard or hazard in addition to the primary hazard.
Some hazardous materials have more than one hazard designated to them. For example Chlorine gas has 3 hazards associated with it. The primary hazard is 2.3 but it also has subsidiary hazards of 5.1 (oxidizer) and 8 (corrosive).
Not all hazardous materials that have a subsidiary hazard are required to be placarded for their subsidiary hazard. There are only three specific times that you MUST placard for subsidiary hazards.
The first are Hazardous materials that are poisonous by inhalation. That would be hazard classes 2.3 and 6.1
The second are hazardous materials that are Dangerous When Wet, hazard class 4.3
The last hazardous material that requires a subsidiary placard is Commodity Specific. In other words, you have to be hauling this very specific product, Uranium Hexafluoride. In addition to using a radioactive placard, Uranium hexafluoride requires a Corrosive placard.
The corrosive placard is only required as a subsidiary hazard for Uranium Hexafluoride, specifically. Any other time a hazardous material with a corrosive subsidiary hazard is not required to be placarded for Corrosive. Did I beat that horse enough?
Back to the Chlorine gas example; I mentioned earlier. It’s primary hazard class is 2.3 with subsidiary hazards of 5.1 and 8. Since none of the subsidiary hazards are any of the big 3, no subsidiary placard is required for Chlorine.
If you have any amount of a hazardous material that has a subsidiary hazard of the above three materials, you must use a subsidiary placard for it.
Once you have to use a subsidiary placard (again, any of the above 3) you must placard the primary hazard also. It doesn’t matter what table it’s on or how much you have, you must placard for the primary and subsidiary hazard.
You can permissibly placard for all other hazards if you want to. Just make sure that you display the placards as required.
It’s important to remember that the Dangerous placard is an option not a requirement. Keep in mind that you must always consider basic placarding first and then figure out whether or not you can use a Dangerous placard.
To use the Dangerous placard, you must meet the following requirements:
1. The material must be NON BULK. Never put these on a tanker, an IBC (tote) or portable tank for example.
2. You must have 2 or more categories (hazard classes) or Table 2 hazardous materials onboard that require different placards.
3. You can’t have more than 2,205 pounds aggregate gross weight of one hazard class onboard loaded at one facility. Remember the definition I gave earlier on aggregate gross weight.
The most common violation happens with number 3.
The vehicle gets loaded at one facility (or shipper) with 3,000 pounds (I just picked a random number over 2,205) of a hazard class 3 Flammable. You would no longer be able use a Dangerous placard to cover that Flammable material.
These are items right out of the regulations on how placards are required to be displayed.
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Here is list of a few things to remember when you’re placarding your vehicle and transporting hazardous material in general.
Now reach around and pat yourself on the back for having read down the page this far!
So let’s summarize this beast.
To be in compliance with hazmat placard regulations, you need two key pieces of information;
1. The hazard class and/or division of the hazardous material
2. The weight of the hazmat to determine if the material is in a bulk or non bulk packaging.
This information can be found on your hazmat shipping papers that you were (or should have been) provided. If you don’t have hazmat shipping papers, you need to ask someone what’s going on!
Hazardous materials can’t be shipped or transported without shipping papers.
After you look at your shipping papers to see what you have, then determine what table it’s on.
Table 1: you must placard for any amount
Table 2: 1,001lbs or aggregate gross weight
Computer programs and apps are great but there’s no substitute for knowing what the basic DOT placard rules are.
Getting placard violations are one of the biggest things that get hazmat haulers placed out of service and extra CSA points on their record.
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I've been in law enforcement and teaching DOT stuff to inspectors, drivers and companies for over 20 years. When I'm not doing that, I hit the road and travel on my Goldwing.