Home Podcasts THMG052 – 49 CFR, Part II

THMG052 – 49 CFR, Part II


In part two of this two-part series, we review the federal codes and regulations surrounding transport and placarding.

Complete Show Notes

4:05 More on ORM-D

  • This is a marking for mail or shipping in the United States that identifies other regulated materials for domestic transport only
  • The size, form, quantity, and packaging limit the package label – it also has a limited hazard during transport
  • A consumer commodity is a hazardous material that’s packaged and distributed in a quantity and form intended or suitable for retail sale and designed for consumption by individuals for their personal care or household use purposes – can include certain drugs and medicines
  • Both UPS Ground and FedEx Ground don’t require a hazardous shipping contract to ship ORM-D packages, except to Alaska and Hawaii
  • The USPS will accept ORM-D packages only for materials intended for domestic surface transportation – prohibited in international mail
  • It’s impossible to have an ORM-D that doesn’t fit the criteria for a limited quantity – these materials have to be determined to be limited quantity, and then it’s determined if it can be reclassified further to become an ORM-D
  • If the item can be reclassified as ORM-D, the proper shipping name is usually (but not always) “Consumer Commodity” (see 172.101 in the table
  • Other proper shipping names for ORM-D material are “cartridges,” “small arms,” and “cartridges power device”
  • These products will no longer fall under one of the 9 hazard classes – its hazardous class or division is now ORM-D

8:50 Markings

  • All of the available information on markings in the 49 CFR is found in sections 172.300 through 172.338 and also in 180.415
  • Marking refers to identifying the container for someone to read and react to – it’s important to mark all four sides of a tank or container – exceptions to this are detailed in 172.336
  • A 4-digit number might be shown on an orange and black panel in proximity to the placard – this explains why we don’t always see 4-digit numbers accompanying the placards
  • 4-digit number can also be found in the middle of the placard – this is allowed, but not mandated
  • Cargo tanks transporting compressed gasses or cryogenics MUST be marked on the sides and ends with the proper shipping name or an appropriate common name
  • Specification MC330 and MC331 must be marked “QT” or “NQT” to indicate whether they can hold certain materials – QT is tougher and brittle, while NQT is ductile, soft, flexible, and weaker
  • The test date markings indicate the type and date of testing – must be placed on a metal certification plate at the head of the cargo tank (read more in 180.415)

17:25 Labeling and Placarding Requirements

  • Labels
    • Labels are usually placed on packages (like boxes and drums)
    • To find out whether the product should have a label or a placard, check out column 6 in the Hazardous Materials Table – if it says “none,” there’s no need for a marking
    • In certain instances, even though column 6 states that there should be a label assigned, it’s not always the case – this is because there’s a conflict and another section may release the need for the label (read more in 172.400a)
    • If the hazard fits in 2 categories, you may be required to attach a second label – Class 1 and Class 2 materials require a subsidiary label (see 172.402a)
    • Labels must display the primary hazard class number or division in the lower corner of the diamond – however, labels indicated subsidiary hazards must not have a hazard class number or division number displayed in the second one
  • Placards
    • Everything you need to know about placarding can be found in 172.500 through 172.519
    • Placards must be displayed on cargo tanks that are transporting hazmats
    • To figure out what you have to include in the placard, check column 3 in the Hazardous Materials Table
    • When you find it, flip to 172.504 (Placarding Tables) and check which placard must be displayed – check table F as well to see if there are any exceptions
    • Check out sections 172.519 through 172.560 to learn what each placard means – specifies what they look like (color, font, and dimensions) and also addresses permitted modifications
    • Placards must remain on a cargo tank regardless of how much of the commodity remains in the tank after offloading – doesn’t need to be marked if it’s cleaned and purged, of course
    • Placarding doesn’t apply to infectious substances, ORM-D limited quantities, and combustible liquids in non-bulk (see 173.13 for more information)
    • You must placard any table 1 material in any quantity
    • Placard any shipment of 5,000 pounds or more of any table 2 material loaded at one loading point

28:35 Cargo Tank Specifications

  • You can read more about this in sections 173.24, 173.24b, 173.29, and 180.405
  • Hazmats have different chemical and physical properties, which requires us to handle them differently – as a result, we’ve created containers that aid us in handling these materials
  • Once we know the proper shipping name, we can check column 8 in the Hazardous Materials Table for requirements regarding specification packaging
  • Column 8 s divided into several sections
    • Column 8a is usually filled with exceptions
    • Column 8c gives you specific bulk packaging options
    • If you read one, you must read the second – they’re closely involved

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