This is probably one of the most thorough guides you’ll read on the net about hazmat placard regulations and it’s a crowd favorite.
Two things have remained consistent over the years with DOT placarding:
- No major regulatory updates have occurred for placarding; The basics are the same.
- Just about everyone from multi-million dollar shippers and carriers, owner operators and drivers are still confused about this subject.
Hazmat placard regulations on the surface seem simple, but they’re not (I guess we have attorneys and lobbyists to thank for that).
The purpose of this guide is to show you how to check compliance without expensive software or the next fancy pants phone app.
The thing is, once you understand how to check compliance, it’s really not that hard.If you’re a company that has its own hazmat training program, this is a topic you should spend more time on, it can save you some headaches in the end.
- Why Hazmat Placards Matter
- Reading A Hazmat Shipping Paper
- DOT Placarding Tables
- When to placard for Table 1 hazardous materials
- Table 2 Hazardous Materials: When To Placard
- DOT Placarding Example
- A common placarding mistake
- Subsidiary Hazard Placarding
- Dangerous placard rules
- Dangerous Placard Quick Example
- DOT requirements for placard display
- 10 quick tips for Hazmat Placard Regulations
Why Hazmat Placards Matter
Besides communicating the hazard, hazmat placards can determine other compliance issues such as:
- Whether or not you need a hazmat endorsement on a CDL
- Additional Federal and State permits,
- How many DOT regulations get applied to you.
Applying the wrong placards to the load, not displaying enough of them or displaying them improperly, can potentially get you placed out of service under CVSA guidelines. Of course if you’re placed out of service, it can cost you time or money, or both.
Did I mention CSA points? Yep, you’ll rack up a bunch of those too. In fact, add two extra points if your placed out of service.
Three basic things that determine DOT placards
For basic placarding purposes, there are three key pieces of information that you need to know right under your nose – in fact, right on the paperwork that was handed to you.
Every shipment contains these key pieces of information. Identifying this information and knowing how to use it will go a long way to determining placards and checking compliance.
Reading A Hazmat Shipping Paper
Now that we have an idea of what information we need, let’s take a look at some paperwork.
In the picture, we see a shipping paper with two hazardous materials that are highlighted. The shipping papers list the following:
- Hypochlorite Solution (a fancy term for bleach)
- Corrosive Liquid Basic, Inorganic
Those are called “proper shipping names” in the regulations.
These three pieces of information that we need to know are:
- The hazard class and/or division (if a division is appropriate);
- Total Weight of each hazardous material;
- The type of package that it’s in, either bulk or non bulk.
Now that we’ve taken a look at our hazmat shipping paper, let’s take a look at each of these a bit closer.
DOT Hazard Classes and Divisions
The hazard class is required to be listed right after the proper shipping name. In this case, the material is in hazard class is 8 (which is a corrosive) for each of the materials listed on the shipping paper.
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 any DOT placard or hazmat label..If it’s hard to see on the shipping paper, hazard class 8 is right after the word “solution” in the proper shipping name for “Hypochlorite Solution” and right after the words “Sodium Hydroxide” shown in parentheses for Corrosive Liquid.
Knowing the hazard class will help find the right placard that will go with the hazardous material listed on the shipping paper.
Think of a hazard class or division as a category (or bucket) for hazardous material. Divisions are subcategories of a hazard class.
Hazard Class Divisions
This is because some hazardous materials have different levels of risk 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
This is because there is a varying degree of risk when dealing with explosives. TNT (1.1) is more unstable and makes a bigger boom than bullets for your guns (1.4)
Gases (hazard class 2) are divided into 3 divisions: Flammable gas, non-flammable compressed gas and poison gas
See how it works?
It’s good to get acquainted with hazard classes and divisions, you’ll see them all over the place when it comes to hazmat compliance no matter what mode you’re shipping in (ground, air or water).
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.
Think about this;
Wouldn’t it be nice to know what’s parked next to you or what you’re parking next to. You might want 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 and you understand its properties.
Note that the ORMD designation will be completely phased out by 2021 and replaced with the “Limited Quantity” designation.
What Is the Weight Of the Hazardous Material?
Next, we need to know how much the hazardous material weighs (package and its contents) because this helps to determine whether or not we’ll have put placards on in the first place.
So for our Hypochlorite Solution entry above, we have 600lbs, spread over several packages.
For the Corrosive Liquids entry a total of 378lbs is listed.
As we’ll see later on in this article, this particular load did not require placards.
Hazmat Packaging: Bulk or Non Bulk?
In hazmat, the size of the package matters.
We need to figure out if the packages are bulk or non bulk. For the previous example it appears that these are on skids and in cartons, which indicate individual non bulk packages.
Knowing the difference is one of the most fundamental things in hazardous materials compliance that you must know.
Placarding rules differ on whether or not the material is in a bulk or non bulk packaging.
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.
Here’s a quick recap:
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:
Non bulk hazmat is obviously going to be less than the figures I just gave you. In my article hazmat bulk packaging 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. I’ll wait.
Placards are broken into two groups (“tables’ as they are referred to in the DOT regulations), by their hazard class. Let’s take a look at those.
DOT Placarding Tables
At its core, the dot hazmat placard regulations are pretty simple. The hazmat regulations break placards into two distinct groups (or tables) 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
Table 1 placards represent the major bad boys of the hazardous materials world and are generally items that I affectionately refer to as the “kill you now” materials. Poison gases, volatile explosives for example, need to be taken seriously.
Table 1 hazmat:
- 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 of the table 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 different!
Why would knowing the name make a difference?
Look pretty much the same right? If your paying attention, there’s a subtle difference.
What’s In A Name
A common mistake that drivers 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.
Why does it matter?
For starters, the phrase “Inhalation hazard” is 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.
When to placard for Table 1 hazardous materials
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 half pound, a pound, 900lbs, 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…
Other Things to remember about Table 1 hazardous materials
You’re going to need extra hazardous materials permits. In fact you will need at least one permit or possibly two federal permits, depending on the product you’re hauling.
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.
Table 2 Hazardous Materials: When To Placard
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.
Here is a graphic of Table 2 hazardous materials:
What is aggregate gross weight? It simply means that you add up the weight of all packages plus their contents and include that towards the 1,001 pounds.
DOT Placarding 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.
A common placarding mistake
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 will receive a violation and maybe placed out of service.
Subsidiary Hazard Placarding
The word ‘subsidiary’ means secondary, subordinate or in addition to. So a subsidiary hazard is a secondary hazard or hazard in addition to the primary hazard.
Quick example with Chlorine:
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). That doesn’t mean that you have to placard for them as you’ll find out.
Not all hazardous materials that have a subsidiary hazard are required to be placarded for their subsidiary hazard.
When Do You Use A Subsidiary Placard?
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.
A Subsidiary Placard Rule To Remember
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.
In other words, treat like it’s on Table 1.
You can permissibly placard for all other hazards if you want to. Just make sure that you display the placards as required.
Dangerous placard rules
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? It applies here to.
The most common violation happens with number 3.
Dangerous Placard Quick Example
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.
DOT requirements for placard display
These are items right out of the regulations on how placards are required to be displayed.
- Placards must be displayed on all 4 sides of a transport vehicle. The front placard can be on the front of the trailer or the front of the truck.
- They must be visible from the direction they face while looking at the vehicle. For example, if you’re looking at the left side of the trailer/vehicle, you should clearly see the placard.
- Placards must be securely attached to the vehicle and not flopping in the breeze or about to come off.
- Have to be located away from appurtenances and devices. That’s federal-ease for being clear of ladders, pipes and other attachments of the trailer so that they’re not obscuring the placard.
- Any lettering or numbers on the placard (when required) must read horizontally, left to right.
- Be maintained in good condition; They need to be clean, not torn up and the right color. Pink does not pass for red.
- Have to be on a background so that the color clearly contrasts or must have a dotted line or solid line border. A good example is a flammable placard on the side of a trailer that has a code ad. The flammable placard has a solid white line that sets the placard apart from the ad, so it’s legal.
- Hazmat placards must be at least 9.84″ on each side with the border .5″ form the edge.
- Text on placard (such as “flammable”) is not required on placards unless it is Radioactive (class 7), Dangerous (that text is required). If you’re hauling Oxygen, you can leave the text off if you are displaying the specific identification number for Oxygen.
10 quick tips for Hazmat Placard Regulations
Here is a list of a few things to remember when you’re placarding your vehicle and transporting hazardous material in general.
- Look at your shipping papers, then look at your truck. What hazard class is on the paperwork and what placard do you see?
- Not hauling hazmat or just picked up a new trailer? Make sure on your pre-trip that there are no leftover placards. They’re hard to get off, so I recommend duct tape to cover up what’s left over.
- Do not display “Drive Safely” placards. It can be confused with other placards and hasn’t been legal in years, but many vehicles still have them.
- Make sure the placards you have on the trailer match the paperwork. If your paperwork says “UN1263 Paint, 3” which is flammable, you shouldn’t have a flammable gas placard on the truck. They look exactly the same, except that flammable gas is in hazard class 2, and the paint is in hazard class 3.
- Trouble keeping your placards in the holder? DO NOT use coat hangers!. I recommend clear packing tape. It’s clear (of course) which means it won’t obscure the placard. Watch for discoloration.
- Yes, you can placard permissively. Just know that when you do, you must follow all the placard rules for display.
- Shippers are required to give you placards unless you are already transporting the same hazmat and have those placards on your truck already.
- Make sure your hazmat endorsement is good. In some states the endorsement expires before the CDL does.
- Be sure all of your required hazmat permits are up to date. If you’re not sure, ask the company.
- Make sure you have your Emergency Response Guidebook, Safety Safety Data Sheet (SDS) or some other emergency response information within your reach.
- Companies or employers, make sure all of your people are getting hazmat training. It’s required by DOT and OSHA.
So let’s summarize this beast.
To be in compliance with hazmat placard regulations, you need three key pieces of information;
- The hazard class and/or division
- Total Weight of each hazardous material or each hazard class;
- The type of package that it’s in, either bulk or non bulk.
This information can be found on your hazmat shipping papers that you were 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, unless there’s a specific exception for it..
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.
Placarding violations have remained one of the biggest reasons that drivers and companies both have racked up CSA points in the Safety Management System. Getting placed out of service will get extra points added on.