Three Table 2 Materials, One Damaged Label, and a Ten-Minute Departure
You are loading at a chemical distributor for a multi-stop run in a dry van. The manifest totals: 1,100 lb gross of UN1263, Paint, 3, PG II, in non-bulk pails; 1,300 lb gross of UN1789, Hydrochloric acid, 8, PG II, in non-bulk drums; and 700 lb gross of UN3082, Environmentally hazardous substance, liquid, n.o.s. (contains copper sulfate), 9, PG III, in non-bulk pails. All three are Table 2 materials. At the dock you find one hydrochloric acid drum whose label has been torn off entirely, and the paint pails carry a FLAMMABLE LIQUID label so scuffed that the class number is hard to read. The bill of lading lists each item with quantities and an emergency response telephone number. Dispatch calls and asks whether you can clear the yard in 10 minutes, because the first receiver closes at noon and the next appointment is tight.
1. What placards does the loaded vehicle require, and what alternatives does the regulation give you?
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Add the Table 2 quantities: 1,100 + 1,300 + 700 = 3,100 lb gross. Each individual class except Class 9 exceeds 1,001 lb, and the combined Table 2 total exceeds 2,205 lb.
That opens two lawful options under 172.504(c):
- Specific placards: FLAMMABLE (Class 3), CORROSIVE (Class 8), and CLASS 9, each on both sides and both ends; or
- The DANGEROUS placard, which may be used in place of the specific Table 2 placards when 2,205 lb or more of two or more Table 2 hazard classes are loaded together. DANGEROUS also goes on both sides and both ends.
Either choice is compliant. Many carriers default to DANGEROUS for a mixed load because it reduces placard inventory and the risk of a missing or wrong placard, but it is less informative to emergency responders, so some carriers prohibit it by policy. Check company policy before choosing.
What is not an option is leaving the vehicle unplacarded on the theory that "no single class is that big" or that non-bulk packages do not count. They do count. Placards must be legible from 50 feet and kept upright.
2. What do you do about the missing acid label and the scuffed paint labels before departure?
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The load cannot move as it sits. Section 172.400 requires each non-bulk package of a labeled hazard class to bear the required label, and 172.406 requires labels to be durably applied, printed, or marked on the surface, unobscured, and legible. A drum with no label and a label whose hazard class number cannot be read fail that standard: a responder or a DOT inspector cannot identify the hazard.
The fix is not to write "CORROSIVE" on the drum with a marker, tape a photocopy to the lid, or hope the shipping paper covers it. The correct actions are:
- Ask the shipper to apply a replacement label, or supply replacement labels that are applied to the correct location on the package; the shipper, as offeror, is responsible for the packaging being properly labeled.
- If replacement labels are not available, set that drum off the load and correct the shipping paper so the piece count and total quantity match what you actually carry. Never carry an undescribed or mislabeled package so the paperwork stays tidy.
- Confirm the paint pails' labels are legible after replacement; if the class number is unreadable, treat them the same way.
Ten minutes is not a reason. Document the delay and notify dispatch of the corrected departure time.
3. The Class 9 entry reads "Environmentally hazardous substance, liquid, n.o.s. (contains copper sulfate), 9, UN3082, PG III." Is that description complete, and what else should you verify on the paper?
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The entry is largely correct: for an n.o.s. entry, 172.203(k) requires the technical name of the hazardous material to follow the proper shipping name in parentheses, and "contains copper sulfate" supplies it. The sequence - proper shipping name, class, UN number, packing group - is right, and PG III matches the UN3082 entry for a liquid environmental hazard.
Still verify:
- Total quantity and package count for every entry, and that they match the freight actually on the trailer after any drum is pulled.
- The emergency response telephone number is present and monitored at all times the shipment is in transit, including nights and weekends (172.604). A number that reaches a receptionist at 09:00 Monday does not comply.
- Consistency of hazard class with the labels actually applied, and with the placards you plan to display.
- The Class 9 threshold question. Class 9 is a Table 2 entry; 700 lb alone would not trigger a CLASS 9 placard, but it does count toward the 2,205-lb DANGEROUS threshold, so it affects the placard decision even though it is small.
Correct the paper and the packages together, then leave.