from here to there: topics in transportation to drums (e.g., 1A1), cylinders (e.g., DOT-39 NRC), boxes (e.g., 4GY) or even aerosol cans (e.g., 2P, 2Q, 2S). A “marking” can also refer to a fumigation warning applied to freight containers that are being carried while actively under fumigation, or a marine pollutant mark applied to indicate that cargo is particularly hazardous to the aquatic environment. “Panels” are orange rectangles with Marine pollutant marking a thick black border into which you apply the four digits of the UN or NA identification number, and which are applied to bulk packaging or cargo transport units carrying bulk quantities or certain threshold amounts of dangerous goods. A Limited Quantity marking is a symbol, applied to packages in a square or diamond (preferred by DOT, however required internationally) configuration. It is used to indicate that the products within the combination packaging are dangerous goods that are packaged in a form that is suitable or intended for retail distribution and that have a lesser risk than fully regulated products and quantities of the same substance. The “enlarged” limited quantity marking may be applied to cargo transport units—such as trailers or freight containers— by surface, but are required when freight containers are interchanged at the marine terminal for lifting onto the cargo ship. The “enlarged” limited quantity marking is applied to each of the four visible sides of the freight container in the same manner as placards; however, the Limited Quantity Marking on a freight container means that all of the dangerous goods within the container (regardless of cubic volume) are in limited quantities. It is important to note that it doesn’t matter how many pallets of limited quantities may be shipped in a freight container—it may be one pallet or 20, up to the maximum allowable payload for the freight container. If any amount of the cargo within the freight container requires hazard warning labels, then the “enlarged” limited quantity markings would not apply to the freight container, but rather the freight container must be placarded on the four visible sides for the cargo requiring the hazard warning labels. In a sense, you would never have a situation where the hazard warning placard and limited quantity marking would appear on a freight container at the same time. For example, a typical 20' closed freight container can carry up to 30 cubic meters (or 20 pallets that are five deep, two wide, two high). Let’s assume, in this case that three pallets contain 100 boxes, each containing twelve 16.9oz (500 mL) flammable aerosols. The remaining 17 pallets do not contain hazardous materials of any type. The Limited Quantity Marking would be applied to each of the four visible sides of the freight container. However, if I have three pallets of the flammable aerosols previously described, have 16 pallets of non-dangerous goods, and add one pallet containing 27 five-gallon pails of a solvent-based (flammable liquid) paint, the freight container no longer contains dangerous goods that are only in limited quantities. Therefore, it must be placarded on all four sides with the Flammable Placard and the Limited Quantity Marking would not apply. Hazardous Materials Endorsements The U.S. Federal Motor Carrier Safety Administration (FMCSA) is the regulatory agency that develops and enforces the requirements for licensing and qualification of drivers, maintenance and inspection of vehicles, carrier safety and fitness, drug and alcohol testing, and drivers’ hours of service. FMCSA is not the regulatory agency that develops the DOT’s Hazardous Materials Regulations (HMR). The HMR is developed by the U.S. Pipeline & Hazardous Materials Safety Administration (PHMSA, pronounced fim-zuh). The DOT’s modal agencies (e.g., Federal Aviation Administration, Federal Railroad Administration, Federal Highway Administration, FMCSA) are the DOT’s enforcement arms for their respective modes of transportation. PHMSA generally enforces the requirements for packaging marking, manufacturing and design, even though each modal agency can equally enforce these requirements. FMCSA requires, under Title 49, Code of Federal Regulations (49 CFR), 383.93(b) that “…an operator must obtain Stateissued endorsements to his/her CDL to operate commercial motor vehicles which are: (1) Double/triple trailers; (2) Passenger vehicles; (3) Tank vehicles; (4) Used to transport hazardous materials as defined in § 383.5, or (5) School buses” Title 49, CFR § 383.5 defines a “hazardous material” as “any material that has been designated as hazardous under 49 U.S.C. 5103 and is required to be placarded under subpart F of 49 CFR part 172 or any quantity of a material listed as a select agent or toxin in 42 CFR part 73.” 1993 Panel signifying UN 1993 Limited quantity marking 28 Spray December 2014
Spray Dec 2014
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