The 800-Pound Load That Still Needs Placards
08:10 at a paint and chemical distributor in Gulfport. You are loading a 53-foot dry van for a run to Hattiesburg and Laurel. The pick ticket shows 8 drums of UN1263, PAINT, Class 3, PG II, 55 lb each (440 lb); 6 drums of UN1789, HYDROCHLORIC ACID, Class 8, PG II, 60 lb each (360 lb); and one 200-gallon DOT 412 portable tank of UN1789, HYDROCHLORIC ACID that the yard crew has already chained down at the nose of the trailer. The shipping paper reads: "UN1789, Hydrochloric acid, 8, PG II, 1,400 lb," followed by a 24-hour emergency response number. Nothing else is listed. The dispatcher tells you, "The drums total only 800 pounds, so no placards are needed on this one, just make sure the tank is strapped." The tank's specification plate is legible. The van has no placard holders on the front bumper, and the rear placard holders are clear.
1. What placards, if any, must be on this vehicle, where must they go, and what is wrong with the dispatcher's 800-pound reasoning?
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Two different rules defeat the dispatcher. First, the placarding threshold in 49 CFR 172.504 is 1,001 lb of aggregate gross weight of all Table 2 materials on the vehicle, not 1,001 lb per class and definitely not 1,001 lb of drums only. Class 3 and Class 8 are both Table 2. The total here is roughly 440 lb of paint plus 360 lb of acid in drums plus about 1,900 lb of acid in the tank (200 gal at about 9.5 lb/gal), which is far above 1,001 lb. Second, a bulk package must be placarded in any quantity, so the portable tank by itself forces a CORROSIVE placard. The result is FLAMMABLE and CORROSIVE placards on both sides and both ends, four placards total. The DANGEROUS placard may be substituted when two or more Table 2 classes are present at or above 1,001 lb, but it can never cover a Table 1 material, and specific placards are always acceptable. Because there are no front holders, use adhesive-backed placards on the front of the van rather than skipping the front end.
2. Is the shipping paper acceptable? Walk through what is missing or wrong before you sign the bill of lading.
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It is not acceptable, and you should not depart with it. Under 49 CFR 172.200 through 172.202, each hazardous material needs a basic description in a fixed order: UN number, proper shipping name, hazard class or division, and packing group, along with the total quantity and unit of measure. Two problems jump out. The 8 drums of UN1263 paint are missing entirely, so the paper does not describe what is actually on the truck. And the acid quantity is wrong: 360 lb in drums plus roughly 1,900 lb in the tank is about 2,260 lb, not 1,400 lb, and the bulk quantity in the tank should be shown as such. The paper also has to carry an emergency response telephone number that is monitored at all times while the material is in transportation (172.604) and the shipper's certification. Have the shipper reissue a corrected paper listing both entries with accurate quantities before you move; a false or incomplete shipping paper is the shipper's violation but your problem at a roadside inspection or a spill.
3. Before you accept the portable tank, what do you check, and what would make you refuse it?
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A bulk packaging is legal only while its periodic inspection and test are current under Part 180. The DOT 412 is requalified on a 5-year pressure-test cycle with annual external visual inspection, so you read the specification plate and the test date stamp and compare them to today. If the last test was more than five years ago, the tank cannot be filled or offered, and you refuse it. You also verify the marked capacity, the UN 1789 identification number markings, and that the lading matches the shipping paper, then confirm the tank is the right lining or material for hydrochloric acid and is not overfilled so that outage (ullage) is maintained for expansion. If the test has lapsed, tell the shipper and your dispatcher, note the refusal, and do not sign for the tank. Tank condition, securement and weight distribution are checked after the paperwork and markings pass.