Shipping Paper, Placards, and a Dead Emergency Number
You are dispatched with a 9,000-gallon cargo tank carrying 3,500 gallons of UN1203 gasoline in compartments 1 and 2 and 2,000 gallons of UN1202 diesel fuel in compartment 3, from a Joliet terminal to a card-lock station in Naperville, about 35 miles. The shipping paper reads 'Gasoline, 3, UN1203, PG II, 3,500 gal' and 'Diesel fuel, 3, 2,000 gal,' followed by an emergency response telephone number. You call the number to confirm it before signing and get a recording: 'this number is no longer in service.' The truck carries FLAMMABLE 1203 placards on all four sides. Your CDL has the N endorsement but not H, and the tank's last leak test was 10 months ago. The dispatcher says the run is short and 'the diesel doesn't really count.'
1. Audit the shipping paper. List what is missing and write the correct entry for the diesel.
Read the worked answer
A hazardous materials shipping paper must show, for each material: the proper shipping name, hazard class or division, UN identification number, packing group, and total quantity, plus the number and type of packages and the shipper's certification. It must also carry an emergency response telephone number that is monitored during transport.
Problems on this paper:
- The diesel line is missing the UN number, the packing group, and the word 'fuel' as part of the proper shipping name. 'Diesel fuel, 3' is an incomplete description.
- The package description should identify the cargo tank and compartment quantities, not just gallons floating with no packaging.
- The emergency response number is disconnected, which makes the shipment noncompliant on its face.
The correct diesel entry is: 'Diesel fuel, 3, UN1202, PG III, 2,000 gal, 1 cargo tank' (with the compartment identified). Gasoline is correct as written: 'Gasoline, 3, UN1203, PG II.'
A shipping paper deficiency is not a paperwork nuisance. If an officer or responder cannot tell what is on the truck, the response to a spill or fire starts wrong. The driver signs for the load; the driver should not sign a paper that does not describe it.
2. Does this driver need the H endorsement, and what placards does the diesel compartment require?
Read the worked answer
Yes, the H endorsement is required. A hazardous materials endorsement is needed to operate a vehicle carrying hazardous materials in a quantity that requires placards. The gasoline alone requires placards, so the N endorsement is not enough, and the 35-mile distance is irrelevant.
The diesel compartment needs its own placard showing FLAMMABLE with UN1202. Do not reason from the 1,001-lb aggregate rule: that threshold applies to Table 2 materials in non-bulk packages. A cargo tank is a bulk packaging, and a tank truck carrying a Table 2 material in bulk is placarded regardless of quantity. So 'the diesel doesn't really count' is wrong twice over: it is 2,000 gallons, and it is in bulk.
Placards must be on all four sides, and the UN number on the placard must match the material in the tank. One FLAMMABLE placard showing 1203 does not cover a compartment of 1202. Since both materials are Class 3, the truck will show both 1203 and 1202 placards in the appropriate positions.
The last leak test at 10 months is still within the annual requirement, so that item is fine. The endorsement and the placards are not.
3. What does the disconnected emergency number require you to do, and what are your options?
Read the worked answer
The emergency response telephone number must be monitored at all times while the shipment is in transport, by a person who either has knowledge of the material or immediate access to emergency response information, such as the ERG guide number for each material. A recording saying the number is no longer in service means the shipment does not meet that requirement, and it cannot legally move as documented.
Options, in order:
- Go back to the shipper and get a working number in writing on the shipping paper before you leave the yard. This is the cleanest fix, and it is the shipper's responsibility.
- If your company subscribes to a registered emergency response service, have dispatch confirm that the number on the paper is the current registered number and that it is monitored.
- If neither can be done before you leave, do not take the load.
What you must not do is write your own cell number on the paper and go. The requirement is a monitored line with access to response information, and a driver in a truck is not that. Document the refusal, the time, and who you spoke with, and tell dispatch the load is on hold until the paper is corrected.