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Who is responsible for placarding?
The question of who is responsible for supplying and applying placards – the shipper or the driver – is one that always comes up in the hazmat world. Let’s look at the requirements.
The HMR
The Hazardous Materials Regulations (HMR) have specific requirements for placarding. 49 CFR 172 Subpart F - Placarding has sections focusing on topics such as:
General specifications for placards;
General placarding requirements;
Prohibited and permissive placarding;
Identification number display on placards;
Placarding for subsidiary hazards; and
Visibility and display of placards.
There is also a section that details requirements for providing and affixing the placards prior to transporting a material requiring placarding. According to 49 CFR 172.506 Providing and affixing placards: Highway:
Each person shipping/offering a driver/carrier a hazardous material for transportation by highway shall provide to the driver/carrier the required placards for the material being offered prior to, or at the same time, the material is offered for transportation unless the driver/carrier's motor vehicle is already placarded for the material as required.
No driver/carrier may transport a hazardous material in a motor vehicle unless the placards required for the hazardous material are affixed as required.
So, who is responsible?
Reading that section, it appears that the shipper/offeror is responsible for supplying the placards and the driver/carrier is responsible for putting them on. Piece of cake, right? Not in the real world.
Sometimes shippers don’t provide placards. Sometimes shippers want them on the motor vehicle right away. And, sometimes drivers don’t have placards for the material they are transporting. It can be a real sore spot in a shipper/carrier relationship. What does DOT say about it?
Clarification/interpretation
The following is an edited excerpt from a letter of interpretation regarding 49 CFR 172.506, asking if a shipper/offeror is required to verify that a carrier’s vehicle is properly placarded prior to leaving the facility:
The HMR does not specify when placards must be applied or removed from a motor vehicle. However, 49 CFR 172.506 specifically states that no driver/motor carrier may transport a hazardous material in a motor vehicle unless the placards required are affixed.Therefore, if a shipper/offeror provides the required placards it becomes the driver’s/motor carrier’s responsibility to affix the placards. If other hazmat is already on the vehicle, then it is the driver’s/motor carrier’s responsibility to affix the proper placards required.
When do the placards have to be offered and/or applied? According to another interpretation:
At any time prior to the vehicle entering onto a road accessible by the public, the shipper/offeror has the opportunity to offer the required placards and the driver/carrier has the opportunity to apply them. The HMR does not require that a trailer being loaded at a facility be placarded as soon as the threshold for placarding is reached.
However, unloading a vehicle is a bit different:
Under OSHA requirements, a trailer that is received containing a quantity of hazmat requiring placards must continue to display the placards as long as there is a placarded quantity in it.