Mixed Load Placarding at the Lexington Dock
Danny is picking up a mixed load at a shipper’s dock in Lexington, Kentucky, for delivery to Nashville. The load consists of 14 non-bulk drums of UN1993, Flammable liquid, n.o.s. (Class 3, PG II), each 55 gallons and weighing about 470 lb gross; 10 fiberboard boxes of UN3264, Corrosive liquid, acidic, inorganic, n.o.s. (Class 8, PG III), 50 lb each; and 6 cylinders of UN1956, Compressed gas, n.o.s. (Division 2.2), 150 lb each. All packages are non-bulk. The shipper has applied one FLAMMABLE placard to the rear of the 53-foot van and tells Danny that “the rest are under the 1,001-pound rule.” Danny has Class 3, Class 8, and Division 2.2 placards in his cab. While checking the load, he finds one Class 3 drum with a torn label and a corrosive box crushed at a corner. The shipper is in a hurry to close the dock.
1. Evaluate the shipper’s placarding decision. Does the load require placards for Class 8 or Division 2.2? Explain the weight rule and the DANGEROUS placard option.
Read the worked answer
The shipment contains only Table 2 materials, so the 1,001-pound exception in 49 CFR 172.504(c) works as an aggregate test for non-bulk packages, not as a per-class allowance. The aggregate gross weight is about 14 × 470 = 6,580 lb of Class 3, plus 500 lb of Class 8, plus 900 lb of Division 2.2, or about 7,980 lb. That is far above 1,001 lb, so the exception does not apply. The shipper’s single FLAMMABLE placard is therefore not enough. Danny must display FLAMMABLE, CORROSIVE, and NONFLAMMABLE GAS placards, or he may use the DANGEROUS placard in place of the individual Table 2 placards for the mixed load. He may not use DANGEROUS to avoid placarding a Table 1 material, but none is present here. Placards go on both sides and both ends of the van and must be readable.
2. What should Danny do about the torn label and crushed box before he signs the shipping paper?
Read the worked answer
A torn label and crushed box are not minor paperwork issues. The label is the package communication; if it is missing or illegible, the package is not properly labeled for transport. The crushed box may have lost its integrity and could leak. Danny should refuse to sign the shipping paper until the shipper replaces the label and either repackages the corrosive or places it in a proper overpack with the required marks and labels. He should not accept a verbal promise that it will be fixed en route. He should note the damage to dispatch and, if the shipper insists, leave the freight behind. After correction, he should verify the shipping description and quantities match the packages and that placards match the load.
3. If the van is loaded and Danny is stopped at a Kentucky weigh station, what placards must be visible and where?
Read the worked answer
At the weigh station, the required placards must be displayed on both sides and both ends of the van. If Danny uses individual placards, that means FLAMMABLE (Class 3), CORROSIVE (Class 8), and NONFLAMMABLE GAS (Division 2.2). If he uses DANGEROUS, he displays DANGEROUS on both sides and both ends instead of the three Table 2 placards. Package labels still remain on the packages. Placards must not be obscured by dirt, load bars, or door hardware, and the DANGEROUS option cannot be mixed with individual Table 2 placards on the same vehicle.