The Four-Entry Load and the Single DANGEROUS Placard
You are the driver of a 26-foot straight truck picking up a mixed load at a regional distributor. The bill of lading shows four fully regulated entries:
- 800 lb gross - UN1263, Paint, 3, PG II, 12 drums
- 250 lb gross - UN1830, Sulfuric acid, 8, PG II, 4 drums
- 1,200 lb gross - UN3480, Lithium ion batteries, 9, 10 cartons
- 40 lb gross - UN1075, Petroleum gases, liquefied, 2.1, one cylinder
The dispatcher says the last driver ran this exact load under a single DANGEROUS placard and "never had a problem." The shipping paper lists all four entries, but the emergency response telephone number line is blank and the shipper has already sealed the trailer doors. You have not yet signed the shipping paper or left the dock.
1. What placards must be on this vehicle? Can the DANGEROUS placard be used as the dispatcher suggests?
Read the worked answer
Sort the load by placarding table first - that drives everything else.
Table 1 (placard required for any quantity):
- UN1075, 2.1, 40 lb. Even 40 lb triggers a FLAMMABLE GAS placard. The DANGEROUS placard may never substitute for a Table 1 placard, and there is no 1,001-lb threshold for Table 1 material.
Table 2 (placard required when the aggregate gross weight of Table 2 hazmat is 1,001 lb or more):
- Paint, 3, PG II = 800 lb
- Sulfuric acid, 8, PG II = 250 lb
- Lithium ion batteries, 9 = 1,200 lb
- Total = 2,250 lb, well over 1,001 lb, so Class 3, Class 8, and Class 9 placards are each required.
The DANGEROUS option: when the aggregate gross weight of Table 2 hazmat reaches 2,205 lb (1,000 kg), a single DANGEROUS placard may replace the individual Table 2 placards. At 2,250 lb you qualify - but only for the Table 2 material.
Acceptable configurations:
- FLAMMABLE GAS + DANGEROUS, or
- FLAMMABLE GAS + FLAMMABLE LIQUID + CORROSIVE + CLASS 9.
Not acceptable: DANGEROUS alone. That leaves the 2.1 cylinder unplacarded and is a violation regardless of what the previous driver did.
2. The emergency response telephone number is blank. What does that mean for you, and what else do you verify before you sign and roll?
Read the worked answer
A blank emergency response number is a show-stopper. 49 CFR 172.604 requires a telephone number for each hazardous material on the shipping paper, monitored at all times while the material is in transportation by a person who is either knowledgeable about the material or has immediate access to that knowledge. An empty line means there is no valid number at all, and it also means your 172.602 emergency response information is incomplete.
Before signing, verify:
- Basic description order for every entry: proper shipping name, hazard class/division, UN/NA ID number, packing group.
- Total quantity and the number and type of packages for each entry (yours shows package counts - good - but confirm the weights match the dock paperwork).
- Shipper's certification is signed.
- Emergency response information is attached to or accompanies the shipping paper, and you have an ERG or equivalent.
Action: do not sign and do not depart. Ask the shipper to reprint the paper with a valid 24-hour number and to break the seal so you can reconcile package counts against the paper - or get written verification of the seal count from the shipper. "The last guy did it" is not a defense; the driver who accepts an incomplete shipping paper owns the violation.
3. Once corrected, where do the shipping papers have to be while you drive, and where do they go when you leave the truck?
Read the worked answer
While driving: within immediate reach while your seat belt is fastened - typically in a pouch on the driver's door or in clear view in the cab. The hazardous materials portion must be kept together and distinguishable: either placed first among the shipping papers or tabbed "Hazardous Materials."
When you leave the cab: the same papers go on the driver's seat or in the door pouch - never locked in a sleeper, never in the trailer, never in a toolbox. The point is that a first responder or enforcement officer arriving at an unattended vehicle can find them instantly.
Two extra points on this load:
- Using the DANGEROUS placard changes nothing about paperwork. The shipping paper still lists all four entries in full.
- Your 172.602 emergency response information and the ERG should travel with the papers, and you should be able to find the guide number for each UN number before you pull out - not at the scene.