Loading and Unloading: Segregation and Securement
You are picking up a mixed load of hazardous materials from a warehouse. The load includes: 10 drums of UN 1263 Paint (Class 3, PG II), 5 drums of UN 1789 Hydrochloric acid (Class 8, PG II), and 20 boxes of UN 3480 Lithium ion batteries (Class 9). The drums are 55-gallon steel drums, and the boxes are 20 kg each. The trailer is a 48-foot dry van with wooden floors and no load bars. The shipper has loaded the drums and boxes, but they are not secured. The shipper says that the load is tight and won't move. You notice that the hydrochloric acid drums are loaded next to the paint drums, and the lithium batteries are stacked on top of the paint drums. The weather is hot (95°F).
1. What are the issues with this loading arrangement, and what must you do before transport?
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Issues: 1) The load is not secured. Hazardous materials must be secured against movement during transportation. You must use load bars, straps, or other securement devices. 2) Segregation: Hydrochloric acid (Class 8) and paint (Class 3) are not incompatible per the segregation table? Actually, the segregation table in 49 CFR 177.848 applies to certain classes. Class 3 and Class 8 are not required to be segregated, but it is good practice to separate acids from flammables to reduce risk. However, the main issue is that the acid could leak and react with the paint or its containers. 3) Lithium batteries (Class 9) stacked on top of paint drums: this is not necessarily prohibited, but the batteries must be secured and protected from damage. Stacking heavy boxes on drums could cause the drums to deform or leak. Also, lithium batteries are sensitive to heat; 95°F is not extreme but could affect them. 4) The trailer has wooden floors; you should use a floor liner or ensure no spills can be absorbed. Before transport, you must secure the load, rearrange if necessary to separate incompatible materials (though not required by segregation table, it is prudent), and ensure batteries are not crushed. You should also check that the drums are closed and not leaking. You should inform the shipper that the load must be secured and possibly reloaded.
2. What placards are required for this load, and how should they be displayed?
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The load contains Class 3 (Paint, 10 drums), Class 8 (Hydrochloric acid, 5 drums), and Class 9 (Lithium batteries, 20 boxes). Placarding requirements: Class 3 flammable liquid: 10 drums of 55 gallons each = 550 gallons. The placarding threshold for Class 3 is 1,001 pounds. The weight of paint is not given, but assuming a typical density of about 8 lb/gal, 550 gal = 4,400 lb, which exceeds 1,001 lb, so FLAMMABLE placard is required. Class 8 corrosive: 5 drums of 55 gal = 275 gal. Hydrochloric acid density about 10 lb/gal, so 2,750 lb, which exceeds 1,001 lb, so CORROSIVE placard required. Class 9 lithium batteries: 20 boxes of 20 kg = 400 kg = 880 lb. The placarding threshold for Class 9 is 1,001 lb, so no placard required for Class 9 (unless it's a bulk package, but these are boxes). However, if the total weight of Class 9 exceeds 1,001 lb, placard required; here it's 880 lb, so no. But note: lithium batteries may require a lithium battery mark, not a placard. So placards required: FLAMMABLE and CORROSIVE. They must be displayed on both sides and both ends of the trailer. The placards must be the correct specification. Also, the driver must ensure the placards match the shipping papers.