Placarding a Mixed Table 1 and Table 2 Load
You are loading a straight truck at a HazMat distributor in Harrisburg. The load is 15 steel drums, 150 lb gross each, of UN1993 Flammable liquid, n.o.s., Class 3, PG II (2,250 lb), 10 fiberboard boxes, 100 lb gross each, of UN3264 Corrosive liquid, acidic, inorganic, n.o.s., Class 8, PG III (1,000 lb), and one 5-lb cylinder of UN1017 Chlorine, Division 2.3. The shipper has FLAMMABLE, CORROSIVE, DANGEROUS, and POISON GAS placards. He says, “Put DANGEROUS on both sides and both ends; it covers the whole load and saves placards.” You also notice the chlorine cylinder’s label is faded, and the corrosive boxes are marked with the old UN number UN1760. The terminal is busy, and the dispatcher wants you to leave within 30 minutes.
1. Which placards must be displayed if the carrier does not use the DANGEROUS placard? Explain the thresholds.
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The chlorine is Division 2.3, a Table 1 material, so a POISON GAS placard is required for any quantity. The flammable liquid is Class 3, PG II, a Table 2 material, and 2,250 lb exceeds the 1,001-lb threshold, so a FLAMMABLE placard is required. The corrosive is Class 8, PG III, also Table 2, but 1,000 lb is below the 1,001-lb threshold, so a CORROSIVE placard is not required based on that class alone. Therefore, without DANGEROUS, the required placards are POISON GAS and FLAMMABLE, displayed on both sides and both ends of the vehicle. The DANGEROUS placard may be used instead of the Table 2 placards when the aggregate Table 2 weight is 1,001 lb or more, but it cannot replace the POISON GAS placard for the Division 2.3 material.
2. Can the shipper use DANGEROUS alone for this load? Why or why not?
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No. DANGEROUS may be used in place of specific placards for Table 2 materials when the aggregate gross weight of those Table 2 materials is 1,001 lb or more. It cannot be used for a Table 1 material. Chlorine, Division 2.3, is Table 1, so it must carry the POISON GAS placard regardless of weight. The shipper’s plan would leave the chlorine placarded only as DANGEROUS, which does not communicate the poison gas hazard and is not authorized. At most, the carrier could use POISON GAS for the chlorine and DANGEROUS for the Table 2 portion, but it cannot use DANGEROUS alone. The simplest compliant choice is POISON GAS plus FLAMMABLE.
3. What must be corrected on the packages before the vehicle leaves?
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The chlorine cylinder must have a legible POISON GAS label and the correct UN1017 marking. A faded label is not acceptable because labels must be legible and contrast with the background. The corrosive boxes must be marked with UN3264, not the old UN1760 number, and their labels must match the material being shipped. The shipping paper must also match the corrected packages. If the shipper cannot correct the labels and markings within the loading window, the driver should not leave with the load. The 30-minute departure pressure does not override the marking and labeling requirements; the driver should notify the dispatcher that the load is delayed or rejected until the packages are compliant.