Placarding a Mixed Paint and Chlorine Load in Joliet
At a chemical distributor in Joliet, Illinois, you are assigned a straight truck load: 12 steel drums of UN1263, Paint, Class 3, PG II, each 55 gallons (about 4,800 lb net), and two 150-lb cylinders of UN1017, Chlorine, Class 2.3. The shipper's clerk hands you a shipping paper that lists both items and says, 'You do not need placards for the paint because each drum is a non-bulk package, and the chlorine is under 500 pounds.' The truck has no placards installed. You are asked to sign for the load and leave within 20 minutes to make a 5 p.m. delivery in Springfield. The chlorine cylinders are loaded upright and braced; the paint drums are not yet secured. The dock is busy and the clerk is impatient.
1. What placards, if any, must the vehicle display? Explain how the HazMat Table and the 1,001-lb rule apply to the clerk's statement.
Read the worked answer
The clerk is applying the 1,001-lb exception incorrectly. Under 49 CFR 172.504, placards are not required for most non-bulk packages on a vehicle only when the aggregate gross weight of all hazardous materials in non-bulk packages is less than 1,001 lb. That test is not applied package-by-package. Here the paint alone is about 4,800 lb gross, so the threshold is far exceeded and the Class 3 paint requires a FLAMMABLE placard. Separately, chlorine is a Division 2.3 toxic gas, and Division 2.3 appears in Table 1 of 172.504; a POISON GAS placard is required for any quantity, so the 'under 500 pounds' argument fails. The vehicle must display both FLAMMABLE and POISON GAS placards before it moves. The fact that each drum is a non-bulk package does not create an exemption; it only makes the 1,001-lb aggregate rule potentially relevant, and the weight defeats it.
2. What shipping paper entries and emergency response information must be present before you move?
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Before moving, verify a shipping paper with a proper basic description in the required sequence: UN number, proper shipping name, hazard class/division, and packing group. The entries should read 'UN1263, Paint, 3, PG II' and 'UN1017, Chlorine, 2.3.' Chlorine also requires the inhalation-hazard notation required for Division 2.3 materials on the shipping paper, and the paper must show the number of packages and total quantity. The emergency response telephone number must be monitored at all times while the material is in transportation; a number answered only during business hours is not enough. Check the shipper's certification and that the emergency response information matches the material. If the paper lacks the 24-hour number or the chlorine inhalation notation, do not sign; have the shipper correct it. Placards must be on the vehicle before departure, not added later.
3. What should you check on the load itself, and what would justify refusing it?
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Walk the load before signing. Check each chlorine cylinder for damaged valves, caps, and leaks; check each paint drum for loose bungs, dents, and staining. Confirm labels are present and match the shipping paper. The paint drums are not secured, so the load is not ready: drums must be blocked, braced, or restrained so they cannot move, and they should be loaded upright. If any package is leaking or damaged, refuse it and have the shipper replace or overpack it. Also confirm the vehicle has the required placards and that the shipping paper and emergency response information are in the cab. Only after those items are corrected should you sign and depart.