Placarded Flammable Liquid Leak and Route Choice
Andre is hauling 4,000 lb of a Division 3 flammable liquid (UN 1993, PG II) in 55-gallon non-bulk drums from Louisville to Lexington. The drums are loaded and blocked in the trailer; the bill of lading lists the proper shipping name, hazard class, UN number, and packing group. Andre has a placarded vehicle. His route planner shows two options: a direct route through a tunnel where hazardous materials are prohibited, or a 22-mile detour. He stops at a truck stop for lunch and parks in the lot, 4 feet from the traveled portion of the public road. While walking around the trailer, he sees a small drip from one drum and a strong solvent smell. The truck stop is in a commercial zone with several restaurants and a repair shop.
1. Is the vehicle required to be placarded, and what placards should be displayed?
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Yes. Division 3 flammable liquid is a Table 2 material, and placards are required at 1,001 lb aggregate gross weight or more. Andre has 4,000 lb, so the vehicle must be placarded. The required placard is the red FLAMMABLE placard for Division 3. The shipping paper must show the proper shipping name, hazard class, UN number, and packing group, which Andre has. The placards must be displayed on both sides and both ends of the trailer as required for the vehicle.
2. What should Andre do about the tunnel route and the detour?
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He must not use the tunnel route. Hazardous materials are prohibited in that tunnel unless specifically permitted, and the placarded vehicle would be in violation. He should take the 22-mile detour and notify dispatch of the delay. The detour is a normal routing cost; it is not a reason to risk a tunnel violation or a worse incident. He should also confirm the detour does not pass through another restricted area.
3. Is the parking location legal, and what should he do about the leak?
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No. A placarded hazmat vehicle should not be parked within 5 feet of the traveled portion of a public road; 4 feet is too close. He should move to a safe parking spot away from traffic and ignition sources. For the leak, he should stop, keep people away and stay upwind, eliminate ignition sources, and call 911. He should consult the ERG and shipping paper, contain the drip only if he can do so safely, and not continue the trip. A flammable liquid leak is an emergency, not a 'watch it' item.