Placards and Shipping Paper Before Leaving Denver
You are the driver of a straight truck at a Denver warehouse, loaded with 18 drums of UN1263 Paint (Class 3, PG II; 4,000 lb gross) and 10 drums of UN1789 Hydrochloric acid (Class 8, PG II; 1,350 lb gross). The shipping paper lists both materials, but the acid entry has no emergency response telephone number and the paint entry shows 16 drums, not 18. The shipper hands you the paper and says the warehouse is closing in 20 minutes. The truck has placard holders on both sides and both ends. The left-side holder still contains a FLAMMABLE placard from yesterday; the right side is empty. You have a CDL with the H endorsement and will travel I-25 and I-70 through the Denver metro. Before you sign and leave, you must decide what is wrong, what the truck must display, and whether the paperwork is legal.
1. Which placards must be displayed on the truck, and where? How do you handle the leftover FLAMMABLE placard?
Read the worked answer
Both loads exceed the 1,001-pound threshold for Table 2 materials: paint is 4,000 lb and acid is 1,350 lb. The truck therefore needs a FLAMMABLE placard for the Class 3 paint and a CORROSIVE placard for the Class 8 acid. Placards go on both sides and both ends of the truck. The leftover FLAMMABLE placard on the left is correct for this load, so it can stay if it is legible and undamaged; it is not a false placard. The right side and both ends still need FLAMMABLE and CORROSIVE. If the old placard were for a class not in the load, it would have to be removed. Display both specific placards; do not substitute a generic placard for a load that has a 4,000-pound Class 3 quantity.
2. What corrections must be made to the shipping paper before you sign? What emergency response information is required?
Read the worked answer
The shipping paper must show the proper shipping name, hazard class, UN number, packing group, total quantity, number and type of packages, and a 24-hour emergency response telephone number. The acid entry is missing the phone number; the paint entry understates the drum count by two. I would not sign until the shipper corrects both entries and initials the changes. The count matters because the shipping paper is the basis for placarding and for emergency responders. The phone number must be monitored at all times during transport, not an office number that closes at 5 p.m. I would also confirm that emergency response information, such as the ERG guide page or SDS, is in the cab and that the paper is within reach.
3. The shipper says the acid is diluted to 20 percent, so it is not regulated and does not need a phone number. How do you respond?
Read the worked answer
Dilution does not automatically remove the material from the hazmat rules. The shipping paper lists it as UN1789, Class 8, PG II, so the shipper has already classified it as regulated. If the shipper now claims it is not regulated, the shipper must provide a new classification and documentation; I cannot simply accept a verbal claim. A 20 percent hydrochloric acid solution may still be corrosive depending on concentration and pH, and the UN number and packing group on the paper control. Until the shipper provides a corrected, signed paper or a written determination, I treat it as Class 8 and require the emergency response phone number. If the shipper refuses, I do not haul the load.