FAQs answered by Mike Atkinson Are the placarding requirements the same for Table 1 and Table 2 materials?
No. Table 1 materials must be placarded when transporting any amount regardless of the size of the package. Table 2 materials must be placarded when transported in a bulk package or in a non-bulk package and the aggregate gross weight of all Table 2 materials meets or exceeds 1,001 pounds. What materials make up placarding Table 1 and Table 2?
Table 1 consists of Divisions 1.1, 1.2, 1.3 explosive materials, 2.3 poison gas, 4.3 dangerous when wet, 5.2 organic peroxide (Type B, liquid or solid, temperature controlled), 6.1 poison inhalation hazard, and Class 7 radioactive yellow III label only. Table 2 consists of Divisions 1.4, 1.5, 1.6 explosive materials, 2.1 flammable gas, 2.2 no-flammable gas, 4.1 flammable solid, 4.2 spontaneously combustible, 5.1 oxidizer, 5.2 organic peroxide (other than Type B, liquid or solid, temperature controlled), 6.1 poison (other than poison inhalation hazard), and Class 3 flammable liquid, 8 corrosive, 9 miscellaneous. Is it a requirement for all vehicles that transport hazardous materials to have a copy of the Emergency Response Guidebook (ERG)?
No, regardless of whether your load requires placarding, drivers are not required to have a copy of the ERG.
The Hazardous Materials Regulations (HMR) require emergency response information to accompany most shipments of hazardous materials. The emergency response information can be provided in several ways:
It can be entered on the hazmat shipping papers;
It can be provided in another document, other than the shipping paper, that includes the basic description (and technical name if appropriate) of the hazardous material, such as a Safety Data Sheet; or
It can be provided in a separate document, other than the shipping paper, that cross-references the description of the hazardous material on the shipping paper, such as the ERG.
Although not the original intended use for the ERG, keeping an ERG with the hazmat shipping papers is an easy way for a driver to comply with the emergency response information requirements in the HMR. While it is not mandatory for drivers to use an ERG to comply, many err on the side of caution and carry an ERG in their vehicles to cover any hazmat they may transport.
Are all hazardous materials shippers and carriers required to register with the Pipeline and Hazardous Materials Safety Administration (PHMSA)?
No, only shippers and carriers that meet certain requirements must register. PHMSA registration requirements apply to anyone that offers for transport, or transports in foreign, interstate or intrastate commerce, any of the following:
Any highway route-controlled quantity of a Class 7 (radioactive) material;
More than 55 pounds of a Division 1.1, 1.2, or 1.3 (explosive) material;
More than 1.06 quarts per package of a material poisonous by inhalation (as defined by Section 171.8, that meets the criteria for “hazard zone A” as specified in Sections 173.116(a) or173.133(a));
A shipment (offered or loaded at one loading facility using one transport vehicle) in a bulk packaging having a capacity equal to or greater than 3,500 gallons for liquids or gases, or more than 468 cubic feet for solids;
A shipment (offered or loaded at one loading facility using one transport vehicle) in other than a bulk packaging of 5,000 pounds gross weight or more of one class of hazardous material for which placarding is required; or
A quantity of hazardous materials that requires placards, except farmers in direct support of farming operations.
Products written by Mike Atkinson
Hazardous Materials Compliance Manual
Hazmat Transportation Regulatory Alert