No Hazmat Placards on Mail Trucks: WTF?
By Vance Bennett
All first responder training includes information on US Department of Transportation placarding and labeling. This is an important subject since they are often the first indication of the presence of hazardous materials.
They contain important information such as the hazard class, ID number and hazard class division. Understanding this system is vital in keeping responders safe when dealing with transportation-related hazmat incidents.
Instructors are always faced with a dilemma when they provide hazmat training on DOT regulations — how much detail should they include?
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How much detail do they have to pick from? The DOT hazmat regulations are in Title 49 of the Code of Federal Regulations. The applicable volume of 49 CFR is 960 pages long and it weighs over 2 pounds. That’s a lot of detail.
One topic that invariably comes up has to do with UPS, FedEx, Amazon, DHL or any other private truck company. They are a popular subject for hazmat instructors. These trucks are everywhere and everyone knows what they look like.
When instructors are teaching a hazmat class and get to the section on transportation issues they will often say something to the effect of, “UPS carries more hazardous materials than anyone but you will never see a UPS truck with a hazmat placard.” They will often imply that something illicit has happened to keep DOT placards off these delivery trucks.
DOT compiles statistics on everything you can think of regarding transportation. And, yes, they have data showing how much cargo these companies carry.
According to DOT, the total weight of freight shipments in 2017 (the most recent year data is available) is 17,824,281 tons. Of that, these delivery companies carried 495,680 tons. In graphic terms.
The category of “Multiple modes and mail” includes carriers such as UPS, FedEx, DHL and the US Postal Service. They are the second smallest slice of the pie.
So, do these carriers really ship more hazardous materials than anyone? Uh, no.
But they do carry hazardous materials, and, no, they don’t have placards indicating the presence of those materials.
Why is that? It’s complicated.
The reason why these multiple modes and mail trucks don’t have placards has nothing to do with illicit activities. No bribes to politicians or lobbying by trade association political action committees. The answer is in the DOT regulations.
The requirements for placards are in Subpart F of 49 CFR. It says, “Each person who offers for transportation or transports any hazardous material subject to this subchapter shall comply with the applicable placarding requirements of this subpart.” Note, it doesn’t say, “placard everything.” It says to follow the applicable requirements.
The applicable regulation says to placard “each bulk packaging, freight container, unit load device, transport vehicle or rail car….” These trucks fall into the transport vehicle category. The next part of that paragraph contains the details about why these trucks don’t have hazmat placards. It says a transport vehicle must display the “type of placards specified in tables 1 and 2….”
Tables 1 and 2 divide the hazard classes into two basic categories: bad and worse. The hazard classes listed in Table 2 are bad. The hazard classes listed in Table 1 are worse.
Table 1 includes explosives, poison gas, materials that are dangerous when wet, organic peroxides and certain types of radioactive materials. All of these commodities can be extremely dangerous in the right circumstances — such as if they are on fire. DOT deemed it important to give responders a heads up if a vehicle is carrying these materials.
Table 2 commodities are hazardous but they normally don’t do something extraordinarily bad except under very unusual circumstances. This table is made up of products such as combustible liquids (e.g. diesel fuel), oxidizers (e.g. hydrogen peroxide) and corrosives (e.g. battery acid).
In general, you must placard shipments of Table 2 commodities that weigh more than 1,001 pounds. Less than 1,001 pounds? No placard. Most of these carriers won’t accept a shipment of a Table 2 commodity that weighs 1,001 or more pounds.
What about Table 1 commodities? A placard is required for a shipment that contains any amount of a Table 1 commodity. What types of hazardous materials do these companies not carry? Guess.
Therefore, no placards on all those multiple modes and mail trucks. And, no dodgy conspiracies.
About the Author
Vance Bennett is retired from California Specialized Training Institute, the training branch of the Governor’s Office of Emergency Services. During his 30 years at CSTI he was an Emergency Management coordinator and instructor in the Hazardous Materials Section. He was the course manager for several CSTI courses including Hazmat Incident Commander, First Responder Operations and CSTI Instructor Certification. As the CSTI representative to the FIRESCOPE Hazardous Materials Subcommittee, he helped develop hazmat team typing and equipment standards for California hazmat teams. Vance was also a regular presenter at the Hazmat Continuing Challenge Workshop.
Prior to coming to work for CSTI, he was on active duty in the U. S. Coast Guard specializing in marine safety and pollution response. During that time he was involved in responses to hazmat incidents and oil spills including the EXXON Valdez and American Trader spills. He served in a variety of USCG units including the Pacific Strike Team before retiring in 2009.