January 2008 - Feature

Materials of Trade - Are You Sure You Know the Limits?

By Mike Butsch

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What are the Marking Requirements?

Nonbulk packages, those with a capacity of 119 gallons or less, must be marked with the common name or proper shipping name. Cylinders must be marked and labeled as per HMR mandates. The table can be found in HMR 49 CFR 172.101.

Any diluted mixture of a Class 9 (miscellaneous) carried in a bulk tank (greater than 119 gallons) must be marked on two opposing sides with the four-digit ID number. ID numbers are also found in the hazmat table, and must be displayed on an orange panel or a white square-on-point configuration of the same size as the placard.

What Drivers Must Know

All drivers must know that they are transporting hazardous materials. The MOT exceptions require the operator be aware of the presence of the materials as well as the requirements in HMR 173.6. Many companies choose to cover these requirements as part of orientation. Some organizations cover this issue on a daily check list.

The MOT exception relieves the company of shipping paper requirements and provides relief from other HMR requirements, as long as the hazardous materials transported meet the MOT criteria. If the limits are exceeded, it subjects the corporation to all of the HMR rules. Someone within your organization must be identified as the individual responsible to ensure compliance with hazardous materials regulations. The company should formalize its program concerning the MOTs. If the need arises, this effort will help to demonstrate the company’s compliance with the regulations. WT

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