Twenty-Five Pounds and a Tunnel

Step 1 - the 1,001 lb threshold is aggregate, not per material.

700 + 400 + 500 = 1,600 lb of Table 2 material. That is over 1,001 lb, so the Table 2 placarding threshold is triggered for the vehicle as a whole - not material by material. This is the classic error: a driver looks at 700 lb of flammable liquid, sees a number under 1,001, and concludes no placard.

Required for the Table 2 load: FLAMMABLE (Class 3), CORROSIVE (Class 8), NON-FLAMMABLE GAS (Division 2.2). Because two or more Table 2 categories are present above the aggregate threshold, a DANGEROUS placard may be displayed in place of the specific Table 2 placards - but that substitution applies only to Table 2 materials.

Step 2 - Table 1 has no threshold.

A Division 6.1 PG I material with the inhalation hazard notation is a Table 1 entry. Table 1 materials require placarding in any quantity. Twenty-five pounds is irrelevant. That cylinder requires its own POISON INHALATION HAZARD placard (or POISON, depending on the entry), and that placard cannot be replaced by a DANGEROUS placard.

Verdict on the shipper's claim: wrong on both counts. The 1,001 lb rule does not apply to Table 1 materials at all, and the threshold is measured on the aggregate of Table 2 materials, not on each one separately.

The posted restriction is not a suggestion and it is not negotiable at the wheel. Tunnels are restricted because a release inside one is essentially uncontainable - no ventilation path, no access for responders, and a fire or a heavier-than-air gas cloud in a tube is unsurvivable.

The driver's position:

• The written route plan is the carrier's responsibility, but the driver is the one who will be standing at the tunnel mouth. He must know what is on his vehicle and what the restrictions are before he gets there.
• Some tunnels ban all hazardous materials; others ban specific classes, quantities, or require a permit. Either way, the posted sign controls.
• A Division 6.1 inhalation-hazard load is exactly the kind of material that draws the strictest routing, so this is not a case where 'it's only 25 pounds' has any traction.

What to do: do not enter. Stop in a legal, safe place before the restriction, contact the carrier, and get a legal alternate route in writing. If no alternate can be produced, the load does not move through that tunnel - the driver does not improvise a detour, does not 'go through at 2 a.m. when nobody's checking,' and does not accept a shipper's assurance that it will be fine.

Note the interaction with the placarding question: the vehicle is going to be displaying POISON INHALATION HAZARD whether or not anyone likes the schedule. That placard is going to be read at the tunnel and at every scale.

Do not move the vehicle first. A seeping drum in a lot is a contained problem; a seeping drum in traffic is not. Moving to 'get it away from people' risks spreading liquid, and if the material is flammable you are now creating a vapour trail along a road.

Sequence:

1. Stop the source of ignition and keep people back. For a Class 3, that means no smoking, no running engines nearby, no hot work. Establish a perimeter well beyond the puddle and keep the diner's customers on the far side.
2. Identify the material before touching anything. The shipping paper and the placard tell you the class and the guide number; the Emergency Response Guidebook tells you the initial isolation distance and whether water is appropriate. Never assume it is water-soluble or that water helps - for some corrosives and reactive materials it makes the release worse.
3. Do not attempt to plug, tape, or upright the drum unless you have been trained and equipped for it and the guidebook says it is safe. A drum that is seeping may be under pressure or reacting.
4. Notify: the carrier's emergency number and the shipper, then local emergency services if the guidebook distance calls for evacuation or if the material is an inhalation hazard. Placards stay on - removing them is a federal violation and removes the information responders need.
5. Document what was found, when, and what was done. Post-incident paperwork is how the carrier and the shipper get the drum dealt with and how the next driver learns.

The judgement being tested is the instinct to fix it. The driver's job is to keep people away from it, get the material identified, and hand it to people with the right equipment.