The 1,550-Pound Mixed Load at the Paint Dock
At 6:40 a.m. a driver holding a Class A CDL with the H endorsement arrives at a paint and chemical distributor to pick up a partial load for a hardware store in Wichita. The shipping paper shows three entries: 1,100 lb of UN 1263, Paint, Class 3, PG II; 450 lb of UN 3264, Corrosive liquid, acidic, inorganic, n.o.s., Class 8, PG II; and 200 lb of UN 2810, Toxic liquid, organic, n.o.s., Class 6.1, PG I. All are in non-bulk packages. The shipper has placed one FLAMMABLE placard on each side of the trailer and says the other two materials do not need placards because each is under 1,001 pounds. The shipping paper lists an emergency response telephone number, but it is a general 1-800 number that the shipper admits is not staffed after 5 p.m. The driver is scheduled to cross the Kansas Turnpike and deliver by noon.
1. Which placards, if any, must be displayed on the vehicle, and how does the 1,001-pound rule apply here?
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The shipper is applying the threshold material-by-material. The rule is different.
- UN 2810, Class 6.1, PG I is a Table 1 material. Table 1 materials require the POISON placard in any quantity, so the 200 lb does not escape placarding.
- UN 1263 and UN 3264 are Table 2 materials. The 1,001-pound threshold is measured by the aggregate gross weight of all Table 2 materials in the load, not by each entry. Here the aggregate is 1,100 + 450 = 1,550 lb, which is over 1,001 lb. That triggers the FLAMMABLE placard for the Class 3 paint and the CORROSIVE placard for the Class 8 liquid.
The required placards are therefore FLAMMABLE, CORROSIVE, and POISON. The driver should also confirm they are displayed on both sides and both ends of the vehicle, not just the sides. One FLAMMABLE placard per side is not enough.
2. Can the driver legally accept the load with the emergency response information as described? What should the driver do?
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No. A shipping paper for a hazardous material must include an emergency response telephone number that is monitored at all times while the material is in transportation, or the shipper must have a contract with an emergency response service that can provide the information. A general 1-800 number that is not staffed after 5 p.m. does not meet that requirement unless it is backed by such a contract.
The driver should not sign for or move the load until the shipper corrects the shipping paper. The driver can ask the shipper to provide a monitored number or a contract number for a response service. The driver should also check that the basic description is in the proper order (proper shipping name, hazard class, UN number, packing group) and that the total quantity is shown. If the shipper cannot correct the paper, the driver should refuse the load and notify the carrier. Accepting it and hoping the number works is not a defensible judgment call.
3. The shipper offers to add 300 lb of UN 1325, Flammable solid, organic, n.o.s., Class 4.1, PG II. How does that change placarding?
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UN 1325 is a Table 2 material. Adding 300 lb raises the Table 2 aggregate to 1,850 lb. The load is already over 1,001 lb, so the existing FLAMMABLE and CORROSIVE placards remain required. The new Class 4.1 material requires its own FLAMMABLE SOLID placard; the FLAMMABLE placard used for the Class 3 paint does not cover Class 4.1.
The driver should not simply accept the extra pallet because the trailer already has placards. The shipper must update the shipping paper and provide the additional placard. The driver should verify the new entry and quantity before loading. If the added material changes the loading arrangement, the driver should also check that it is secured and that paper shipping documentation matches what is actually on the vehicle. The key judgment is that placarding is class-specific once the aggregate threshold is met.