Safe Solutions

Transporting hazardous materials

Imagine a tanker full of hot asphalt en route to a job site. The driver obeys the traffic laws; the vehicle is in good operating condition; and the load is sealed securely inside.

Suddenly, a state trooper pulls the tanker over to the side of the road. The state trooper asks the driver about the tanker's contents. The driver says he is transporting more than 1,000 gallons (3800 L) of hot asphalt and presents his commercial drivers license (CDL) and the shipping papers.

The state trooper explains the tanker bears no markings that indicate it contains a hazardous material. As a result, the contractor who owns the tanker could face a civil penalty of a minimum of $250 and maximum of $27,500 for each violation. If a violation continues, each day the tanker is on the road is counted as a separate offense.

According to the U.S. Department of Transportation (DOT), kettles and tankers must be marked in one of the following ways:

  • Markings must be located on two opposing sides with the word "HOT" spelled in black lettering on a plain, white square-on-point configuration that is the same size as the placard. Markings must be in English and free of labels, advertising or trademarks.

  • A kettle or tanker that holds fewer than 1,000 gallons (3800 L) must be marked on two opposing sides with an orange panel or white square-on-point configuration with "3257," which indicates the material being transported is at an elevated temperature.

  • If a kettle or tanker has a capacity greater than 1,000 gallons (3800 L), the markings must appear on the sides and ends.

Because tankers and kettles often are covered in grime, making it difficult to keep markings visible, DOT allows the markings "HOT" and "3257" to be displayed on easily replaceable placard-style signs. A marking should have the same dimensions as a placard and can be inserted into placard holders already in place. DOT allows the markings to be combined on a square-on-point placard with a white background. The word "HOT" should be located directly above "3257."

Driving CMVs

DOT's Federal Motor Carrier Safety Administration defines a commercial motor vehicle (CMV) or combination of motor vehicles as one that is used for business to transport passengers or property if the vehicle has "a gross weight of 26,001 pounds (11,794 kg) or more inclusive of a towed unit with a gross vehicle weight of more than 10,000 pounds (4,536 kg) or has a gross vehicle weight of 26,001 pounds (11,794 kg) or more; or is of any size and is used in the transportation of placarded amounts of hazardous materials."

Another issue contractors should remember is placards on a vehicle indicate the operator must have a CDL, which authorizes a driver to operate a class of CMV of a specific weight or one of any size that transports more than 1,001 pounds (454 kg) of hazardous materials.

NRCA helped develop the DOT regulations that allow operators who haul Class 9 elevated temperatures materials in vehicles below the CMV weight limit to do so without possessing a CDL. Therefore, placards are not required for such vehicles that transport elevated temperature materials domestically. The placard-style markings discussed previously are acceptable instead.

Shipping papers

Even if a vehicle has appropriate markings, a driver may have to possess shipping papers for the load he is transporting. If a kettle or tanker has a capacity greater than 118 gallons (448 L) and content temperatures in excess of 212 F (100 C), shipping papers must be in the vehicle with the following description and format:

Elevated Temperature Liquid, n.o.s.
(Asphalt), UN 3257
P.G. I I I, 1-750 gallon kettle

Although it's unnecessary to list the quantity of material being shipped, a kettle's capacity must be shown as in the example. Also, shipping papers must contain a 24-hour emergency telephone number for a person who can provide emergency response information about the material in case of an accident.

Using caution

Now that spring is here, more roofing tankers and kettles are transporting hazardous materials on U.S. highways. Roofing contractors can avoid needless, costly fines if they ensure those vehicles display appropriate markings and placards and drivers have appropriate licenses and documentation.

Peter Greenbaum is NRCA's manager of education programs.


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