Sylvie Willis
Whether an empty fuel tank truck requires placarding depends on the hazard level of the material, the quantity being transported, and the type of packaging used. If the tanks are \sufficiently cleaned of residue and purged of vapors to remove any potential hazard\, then no placards are required. However, if there is any residual amount of hazardous material, even vapors, then placarding is necessary. In the case of diesel fuel, there is often confusion about whether it is regulated and requires placarding. To comply with regulations, it is essential to understand the differences between bulk and non-bulk packaging, with the former having a maximum capacity greater than 119 gallons for a liquid hazmat.
| Characteristics | Values |
|---|---|
| Placarding requirement | Determined by the hazard of the material, quantity of the material being transported, and type of packaging used |
| Hazardous materials | Require placarding |
| Bulk packaging | No intermediate form of containment, maximum capacity greater than 119 gallons for liquid hazmat |
| Non-bulk packaging | Maximum capacity of 119 gallons or less for liquid hazmat |
| Flammable liquids | May be reclassified as combustible liquids if the flashpoint is at or above 100°F |
| Diesel fuel | Classified as a flammable liquid, may be reclassified as a combustible liquid |
| "Empty" tanks | Not subject to USDOT regulations if not used to transport hazardous materials |
| Certification | Not required to indicate tanks are "empty", but may be useful for inspection |
| Wastewater | May be subject to state regulation, e.g., Liquid Industrial By-Product in Michigan |
| Multiple hazmat loads | Rumored to require separate placarding for each type, e.g., gasoline and diesel |
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What You'll Learn
Regulations for empty fuel tank trucks
Fuel tank trucks are subject to various regulations to ensure safety and compliance during the transportation of hazardous materials such as gasoline, diesel, and other fuels. These regulations cover the proper design, construction, and maintenance of fuel systems, including gravity-fed systems, to minimize the risk of accidents and environmental contamination.
One important regulation for fuel tank trucks is the requirement for a rollover valve, which helps prevent fuel leakage in the event of a vehicular rollover. This valve seals the vent line during a rollover accident, minimizing the risk of fuel spills, fires, and environmental damage. Gravity-fed auxiliary fuel systems, in particular, can benefit from installing a rollover valve to improve overall safety.
Another crucial aspect of fuel tank truck regulations is the need for safety vents or pressure relief devices. These devices are designed to release excess pressure inside the fuel tank in cases of over-pressurization or extreme temperatures. To effectively protect the tank truck and its surroundings, these vents must comply with specific pressure ratings set by regulatory bodies such as the Federal Motor Vehicle Safety Standards and Regulations (FMVSS).
Additionally, fuel tank trucks equipped with multiple fuel tanks require a selector valve, allowing drivers to switch between tanks without physically accessing them. This valve reduces the risk of accidental fuel spills and enhances operational safety and efficiency.
When it comes to empty fuel tank trucks, the need for placarding and certification depends on whether the tanks have been sufficiently cleaned of residue and purged of vapors to remove any potential hazard. If the tanks are considered empty and pose no hazard, placards and certifications may not be required. However, it is the shipper's responsibility to determine if the definition of "empty" has been met, and they may still choose to provide a certificate to inspectors.
To summarize, regulations for fuel tank trucks focus on safety and compliance during the transportation of hazardous materials. Key aspects include the installation and maintenance of safety equipment such as rollover valves, safety vents, and selector valves, as well as compliance with pressure ratings and other standards set by regulatory bodies. Empty fuel tank trucks may be exempt from certain requirements if they are properly cleaned and pose no hazard, but certification and placarding may still be considered for added assurance.
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Hazardous materials and placarding
Hazardous materials are subject to strict regulations regarding their transportation, and this includes specific requirements for placarding. In the US, the Department of Transportation (USDOT) outlines the rules for placarding hazardous materials in the Code of Federal Regulations (CFR). According to 49 CFR § 172.504, any transport vehicle or rail car carrying hazardous materials must be placarded on each side and each end, with the type of placards specified in tables provided in the regulation. These placards are essential for identifying the nature of the hazardous cargo and ensuring its safe transport.
The specific placarding requirements vary depending on the type of hazardous material being transported. For instance, radioactive materials require specific placards for all shipments of unpackaged LSA-I or SCO-I material, as well as for closed vehicles used in accordance with certain regulations. Flammable materials also have their own placarding specifications, where a FLAMMABLE placard may be used in place of a COMBUSTIBLE placard in certain situations. Similarly, for Division 5.1 materials that are also classified as Division 1.5 explosives, an OXIDIZER placard is not necessary if the vehicle is appropriately placarded with EXPLOSIVES 1.5 markings.
In the case of empty fuel tank trucks, the requirement for placarding depends on whether the tanks have been thoroughly cleaned and purged of any hazardous residue or vapours. If the tanks previously contained hazardous materials, such as diesel, even trace amounts of residue or vapours classify the vehicle as transporting hazardous materials. As such, it would be subject to the same placarding requirements as if it were carrying a full load of hazardous cargo. However, if the tanks have been sufficiently cleaned and purged to remove any potential hazard, then no placarding is necessary.
It is important to note that the responsibility for determining whether the tanks are truly empty falls on the shipper. While a certification of emptiness is not required, creating a certificate to provide to inspectors can be beneficial. Nevertheless, if any harmful vapours or residue remain, the vehicle would still be subject to HazMat regulations, including the requirement for placarding. Properly managing and disposing of wastewater generated during the cleaning process is also crucial, as it may be classified as a non-hazardous or hazardous waste depending on the state and local regulations.
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Diesel and other hazardous materials
The US Department of Transportation (USDOT) requires that hazardous materials or 'HazMat' be properly classified, packaged, labelled, handled, and stowed for transportation. This includes materials such as explosives, gases, flammable liquids, and solids. Diesel is considered a combustible liquid and is therefore classified as a hazardous material.
If a fuel tank truck is truly empty, it does not require placarding. However, if there is any residual amount of fuel, vapours, or even a fuel smell, it may be considered a HazMat and be subject to regulation. In this case, the tank would require placarding and the driver should be able to provide a certificate of its contents if stopped by an inspector. It is the responsibility of the shipper to determine if the tank is truly empty and meets the definition of "empty".
To ensure compliance, shippers and carriers can refer to the Safety Data Sheet (SDS), formerly known as the Material Safety Data Sheet (MSDS), prepared by the manufacturer. This document provides the product's hazard classification and transportation requirements. Additionally, consulting a professional tank cleaner can provide guidance on the necessary cleaning and certification processes to ensure that tanks are considered "empty".
It is important to note that the transportation of hazardous materials, including diesel, is subject to specific regulations and may require HazMat Employee training. Proper handling and compliance with USDOT regulations are crucial to ensure the safety of workers, emergency responders, and the general public.
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Bulk and non-bulk packaging
The placarding requirements for the transportation of hazardous materials can be confusing. The requirement is determined by the hazard of the material, the quantity being transported, and the type of packaging used.
Bulk packaging
Bulk packaging has no intermediate form of containment and has a maximum capacity of over 119 gallons (450 litres) of liquid. Bulk packaging always requires some form of placarding to identify the contents of the container. This is so that, in the case of an emergency, first responders know what they are dealing with and how to treat it. In the worst-case scenario of a spill, the label allows responders to know what safety equipment they need and how to approach the clean-up process.
For example, for shipments of Class 1 (explosive) materials by aircraft or vessel, the compatibility group letter must be displayed on the placards. For Class 9, a placard is not required for domestic transportation, but a bulk packaging must be marked with the appropriate identification number on a Class 9 placard, an orange panel, or a white square-on-point display configuration.
A bulk packaging with a capacity of less than 640 cubic feet does not include a portable tank, cargo tank, or tank car. If a bulk packaging is not excepted and placarding is required, then the placards must remain even when it is empty unless it is sufficiently cleaned of residue and purged of vapours to remove any potential hazard.
Non-bulk packaging
Non-bulk packaging has a maximum capacity of 119 gallons or less as a receptacle for a liquid hazmat. Non-bulk packaging of hazardous materials does not require a placard, except for hazardous materials subject to specific regulations.
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Certification and inspections
The US Department of Transportation (USDOT) has strict regulations for the transportation of hazardous materials. These regulations are authorised by the Hazardous Materials Transportation Act (HMTA) and implemented by the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Fuel tank trucks are subject to annual inspections by the DOT to assess the integrity of the tank, valves, and safety systems. These inspections are crucial to ensure safety and compliance with regulations. In addition to DOT inspections, trucking companies are responsible for routine maintenance on mechanical components, including brakes, tires, and steering systems.
Leak testing is a critical aspect of maintenance for fuel tank trucks. Tanks must undergo pressure tests to ensure there are no leaks, and any detected leaks must be repaired immediately before the truck can be cleared for operation.
Cargo tanks used for transporting petroleum distillate fuels and equipped with vapor collection equipment must be leak-tested according to the Environmental Protection Agency's methods. If a tank fails to retain leakage test pressure, it cannot be returned to service unless specific conditions are met.
Insulated cargo tanks with manholes or inspection openings have the option to perform either internal and external visual inspections or hydrostatic/pneumatic pressure tests. Additionally, certain cargo tanks constructed of specific types of steel are subject to a 10-year inspection interval period.
While certifications are not required to indicate that tanks are "empty," it is the shipper's responsibility to determine if the tank meets the definition of "empty." Some shippers choose to create a certificate for the driver to provide to inspectors, but this is not mandatory. If there are any harmful vapors or residues of hazardous materials remaining in the tanks, it is considered HazMat, and the transportation is subject to regulation.
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Frequently asked questions
If the tanks are “sufficiently cleaned of residue and purged of vapors to remove any potential hazard”, then no placards are required.
If there is any residue of a hazardous material (e.g. diesel) in the tank, even vapors, then the transportation is subject to regulation and placarding is required.
The placarding requirement is determined by the hazard of the material, the quantity being transported, and the type of packaging used. Bulk packaging has a maximum capacity greater than 119 gallons for a liquid hazmat, while non-bulk packaging has a maximum capacity of 119 gallons or less.
In the past, only one placard was required based on the lowest flashpoint found in the trailer. However, there is a rumor that loads containing multiple types of hazardous materials will soon need to be placarded separately.
