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Do Class 9 Hazardous Materials Require Placards?

Posted on 4/28/2022 by Roseanne Bottone and Roger Marks

Hazardous materials placards serve a vital function in transportation safety.

In the event of an accident or release during transportation, the basic information on a placard helps emergency responders to:

  • Take effective response actions
  • Choose appropriate personal protective equipment (PPE)
  • Move people away from danger or exposure when necessary
  • Assess short- and long-term risks to the public

It's common to see placards for flammable liquids, corrosives, compressed gases, and various other classes of hazardous material on public roads in the US. But what about DOT Hazard Class 9?

Are hazmat placards required for shipments of Class 9 hazardous materials? In general—no, not in domestic transportation. Still, in some situations—including transportation by vessel—a shipper of Class 9 materials must understand the placarding requirements in order to maintain compliance with US and international regulations.

What Is a Class 9 Hazardous Material?

Hazard Class 9 is the “miscellaneous” class of hazardous materials. Class 9 is comprised of substances and articles that pose hazards in transportation but don’t fit any criteria for Hazard Classes 1 through 8.

Lithium batteries are a Class 9 hazardous material. So are certain chemical and first aid kits, friable asbestos, polychlorinated biphenyls (PCBs), capacitors, and many other materials and articles.

The US Census Commodity Flow Survey (CFS) shows that 70 million tons of Class 9 hazardous materials were transported in the US in 2017, the last year for which data is available. That was enough to make Class 9 the fourth-most-shipped hazard class that year.

Class 9 Placarding Requirements

In general, a hazmat placard must be displayed on any of the following when they contain any quantity of a hazardous material: a transport vehicle, freight container, unit load device, bulk packaging, or rail car (49 CFR 172.504(a)).

That section of the regulations includes a list of exceptions to the general placarding requirement. One of those exceptions applies specifically to Class 9 materials.

A placard is not required for domestic transportation of Class 9 hazardous materials.

(49 CFR 172.504(f)(9))

Class 9’s in Bulk Packagings

When hazardous materials are transported in a bulk packaging—i.e., a cargo tank truck, a portable tank, or an IBC—the package/vehicle must display the material’s UN ID number.

For Class 9 materials in bulk packagings, a Class 9 placard is one of three options for displaying the UN number. An orange panel or a white square-on-point placard that conforms to the requirements in 49 CFR 172.332 may also be used.

Class 9’s With Other Hazardous Materials

US DOT's general placarding requirements separate types of hazardous materials into two tables:

  • Table 1 lists the highest risk cargo—explosives, radioactives, poison gases, dangerous when wet materials, and Type B organic peroxides.
  • Table 2 lists more common hazmat—flammables and combustibles, corrosives, non-poison gases, and others. Class 9 hazardous materials are listed on Table 2.

Placards are not required on vehicles carrying less than 1,001 pounds of Table 2 materials in non-bulk packagings, except in specific circumstances. That’s another one of DOT’s exceptions to the placarding requirement (49 CFR 172.504(c)(1)).

Important: Class 9 materials count toward the 1,001 pound trigger for Table 2 materials.

In other words, if we offer a shipment of 600 pounds of a flammable liquid (Class 3) and 600 pounds of PCBs (Class 9), we have exceeded the 1,001 lb. trigger. The vehicle must display the required placards. Because US DOT does not require a placard for domestic shipments of Class 9 materials, only the Class 3 placard would be required in this example. A DANGEROUS placard may also be used in some cases.

More detail about when hazmat placards are required: Hazmat Shipper Starter Guide.

International Class 9 Shipments by Vessel

When shipping Class 9 hazardous materials by vessel, a placard is required.

Unlike US DOT’s regulations, the International Maritime Dangerous Goods Code (IMDG Code) does not provide an exception for Class 9 materials, nor for shipments of less than 1,001 pounds.

“Permissive Placarding”

US DOT recognizes that in some cases, an international shipment will require placards that are not required within the United States.

DOT gives shippers permission to use a placard, even when one is not required, as long as the hazard is present (49 CFR 172.502(c)). This allows shippers to placard for all hazards at the originating facility, so that a freight agent or forwarder does not have to add or change placards before the shipment is loaded aboard a vessel.

It is the shipper’s responsibility to provide hazmat placards. Transporters often have their own placards to use, but not always. Per the regulations, the shipper must ensure that the vehicle is placarded properly before it leaves. That includes offering appropriate placards when needed.

In summary, while the HMR does not require a Class 9 placard for domestic transportation, a placard is required for vessel transportation per the IMDG Code. These "miscellaneous" materials count toward the 1,001 pound placarding threshold for Table 2 materials in non-bulk packagings. Class 9 hazardous materials are also subject to the requirement to mark bulk shipments with an identification number.

Instructor-Led DOT Hazmat Training

Join a workshop or webinar for live, instructor-led training to ship hazardous materials in full compliance with the latest US and international regulations for ground, air, and vessel shippers.

Prefer to train at your own pace? Choose an interactive, mobile-ready online course to ship hazardous materials, manage hazardous waste, prepare for emergencies, and comply with OSHA workplace safety regulations. Visit Lion.com/Online.

Tags: Class 9, hazardous materials, hazmat shipping, lithium batteries

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