Placarding and Rejecting a Mixed LTL Load in Baton Rouge
At a Baton Rouge dock, you sign for a 53-foot dry van load: 16 drums of UN1993, Flammable liquid, n.o.s. (ethanol), 3, PG II, at 350 lb each; 6 drums of UN3264, Corrosive liquid, acidic, inorganic, n.o.s., 8, PG II, at 400 lb each; and 4 cylinders of UN1005, Anhydrous ammonia, 2.2, at 150 lb each. The shipping paper lists all three. Nothing is a bulk package. The dispatcher says, 'One DANGEROUS placard covers the whole load.' While checking the load, you find the bung on one UN1993 drum seeping. The dock supervisor says it is a tiny drip and tells you to sign and leave; it is 2:00 p.m. and 95°F. The terminal is busy and the gate closes at 3:00 p.m. Your trailer has no placards installed yet.
1. What placards are required, and is the dispatcher's 'one DANGEROUS placard' instruction lawful? Show the quantity and exception analysis.
Read the worked answer
Total aggregate gross weight is 16 × 350 = 5,600 lb, plus 6 × 400 = 2,400 lb, plus 4 × 150 = 600 lb, for 8,600 lb. That is above the 1,001-lb threshold for non-bulk packages, so placards are required. The three categories are Class 3, Class 8, and Division 2.2. Under 49 CFR 172.504(b), when two or more categories require placards, a DANGEROUS placard may be used in place of the individual placards, except for Division 1.1, 1.2, 1.3, 2.3, 6.1 PG I inhalation hazard, and Class 7. Anhydrous ammonia is 2.2 here, not 2.3, so it is not on the exception list. The dispatcher's placarding instruction is therefore lawful-but only if the DANGEROUS placard is properly displayed and the load is otherwise legal. It does not authorize accepting a leaking drum. If the load also contained a 2.3 gas such as chlorine, DANGEROUS could not replace the 2.3 placard.
2. Can you accept the leaking drum and move the vehicle? What must happen before departure?
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No. A leaking package is not in proper condition for transportation, and the carrier must refuse it. The 'tiny drip' is still a release from a flammable-liquid drum in an enclosed trailer at 95°F; vapor can accumulate and the drum can worsen in transit. Signing the shipping paper would tender a leaking package. The shipper must repair or repack the drum, transfer the contents to a sound drum, or overpack it under 49 CFR 173.3 with the proper overpack marks and shipping-paper entry. Inspect adjacent drums for damage. Do not move until the leak is corrected and the package is secured. If the leak had been discovered on the road, you would secure the area and notify emergency responders and the National Response Center as required.
3. What must the shipping paper show for these three materials, and what emergency response information must accompany it?
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Each entry must use the basic description sequence: UN number, proper shipping name, hazard class, and packing group where one is assigned. Examples are 'UN1993, Flammable liquid, n.o.s. (ethanol), 3, PG II'; 'UN3264, Corrosive liquid, acidic, inorganic, n.o.s., 8, PG II'; and 'UN1005, Anhydrous ammonia, 2.2.' The paper also needs the total quantity and the number and type of packages, the shipper's certification, and a monitored 24-hour emergency response telephone number. Emergency response information-such as the appropriate ERG guide or an equivalent-must accompany the shipping paper. Using the DANGEROUS placard does not change any shipping-paper description or emergency response requirement.