Katerina Swanson
When transporting diesel fuel, it is important to determine whether placarding is required. Placards are used to identify the risk of products being transported and must meet the Department of Transportation's guidelines for dangerous goods marking. The requirement for placarding is determined by the hazard of the material, the quantity being transported, and the type of packaging used. Diesel fuel is classified as a flammable liquid, but it may be reclassified as a combustible liquid if its flashpoint is at or above 38°C (100°F). In most cases, diesel fuel transported in non-bulk packaging does not require a placard, whereas diesel fuel in bulk packaging is regulated and does require placarding. Additionally, full diesel loads must be marked with the NA 1993 placard, and they cannot carry a 1203 placard.
| Characteristics | Values |
|---|---|
| Placard size | 10.75" x 10.75" |
| Placard material | Paper tagboard, rigid plastic, adhesive vinyl |
| Placarding requirement | Determined by hazard of material, quantity of material, and type of packaging |
| Diesel fuel classification | Flammable liquid, may be reclassified as combustible liquid if flash point ≥ 100° F (38° C) |
| Bulk packaging | No intermediate form of containment, capacity > 119 gallons |
| Non-bulk packaging | Capacity ≤ 119 gallons |
| Full diesel loads placard | NA 1993 |
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What You'll Learn
Diesel fuel is classified as a flammable liquid
Diesel fuel is a complex mixture of hydrocarbons and can be categorised as either flammable or combustible. The classification depends on the fuel's flash point—the lowest temperature at which vapours of a combustible liquid can be ignited. Diesel fuels generally have a flash point between 52°C and 93°C. Diesel fuels with a flash point below 60°C are classified as flammable liquids, while those with a flash point above 60°C are considered combustible liquids.
The Australian Dangerous Goods Code defines a flammable liquid as a liquid that gives off flammable vapours at temperatures of not more than 60°C in a closed-cup test or 65.6°C in an open-cup test. Flammable liquids are further classified into GHS categories 1-3, which overlap with the ADG code packing groups I-III. An example of a flammable liquid in category 4 is diesel.
The hazardous nature of diesel fuel necessitates specific handling and storage practices. Organisations must adhere to the Australian Standards AS 1940:2017 when using, transporting, and storing diesel fuels. This includes implementing sufficient controls to mitigate the risks associated with flammable or combustible substances. The Flinders Shire Council provides guidelines for the safe storage and handling of flammable liquids, including precautions for minor storage and general design and construction requirements for storage areas.
The placarding requirements for diesel fuel depend on the hazard level, quantity transported, and packaging type. When transported in non-bulk packaging, diesel fuel typically does not require placarding. However, when transported in bulk packaging, diesel fuel is regulated and must be marked with the NA 1993 placard. This requirement also applies to multi-compartment tanks transporting solely diesel fuel.
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Bulk vs. non-bulk packaging
The difference between bulk and non-bulk packaging for diesel fuel primarily concerns the capacity of the packaging. Bulk packaging is a requirement for companies shipping large quantities of chemicals to remain competitive in today's global market. However, it poses more significant health and safety risks, particularly in the event of a spill.
Bulk packaging typically refers to a capacity of over 119 gallons (450 litres) of liquid. This includes tankers, whether as single vehicles or rail cars, which are designed to carry far more than 119 gallons. For example, a standard tanker towed by a tractor-trailer can deliver diesel fuel to individual gas stations. Rail cars can also be linked together to deliver fuel over long distances.
Non-bulk packaging, on the other hand, refers to a capacity of 119 gallons or less of liquid hazardous materials. While non-bulk packaging can also pose health and safety risks, these are not as severe as those associated with bulk packaging.
The placarding requirements for diesel fuel depend on the hazard, quantity, and type of packaging used. Diesel fuel is generally classified as a flammable liquid, but it can be reclassified as a combustible liquid if its flashpoint is at or above 100°F (38°C). When transported in non-bulk packaging, diesel fuel typically does not require a placard. However, when transported in bulk packaging, it is regulated and does require placarding.
It is important to note that the interpretation of placarding requirements can vary. For example, the PHMSA states that full diesel loads cannot carry a 1203 placard and must be marked with an NA 1993 placard. Therefore, understanding the specific regulations and requirements for bulk vs. non-bulk packaging of diesel fuel is essential to ensure compliance and safety.
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Reclassification as a combustible liquid
Diesel fuel is classified as a flammable liquid, but it can be reclassified as a combustible liquid if its flashpoint is at or above 38°C (100°F). This reclassification has serious implications for the fuel industry, as it would require the modification or replacement of all diesel/gas oil storage systems.
The confusion around the placarding of diesel fuel arises from the determination of whether it is regulated or not. The placarding requirement is largely determined by the hazard of the material, the quantity being transported, and the type of packaging used. Diesel fuel is not classified as a dangerous good for transport purposes by the ADG code, but it is classified as a dangerous good for storage purposes. This means that it must be stored in full compliance with the Australian Standard AS1940-2017, which outlines the safe storage requirements for flammable and combustible liquids.
The type of packaging used for diesel fuel also determines whether it is regulated and requires placarding. Bulk packaging has a maximum capacity greater than 119 gallons for liquid hazardous materials, while non-bulk packaging has a maximum capacity of 119 gallons or less. When diesel is transported in non-bulk packaging, it is generally not subject to hazardous materials regulations, and therefore a placard is not required. However, when transported in bulk packaging, it is regulated and does require placarding.
The reclassification of diesel fuel as a flammable liquid under CLP regulations 2015 and the update of HSG 176 caused concerns for the fuel industry. However, the HSE worked with the Fuel Industry Working Group (FIWG) to resolve the issue and released a paper addressing the position. Additionally, a statement provided by the FIWG outlines that when diesel fuel is stored in specific types of storage tanks with a capacity not exceeding 150,000 litres and designed to recognised industry standards, the requirements of HSG 176 do not need to be applied.
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Hazardous materials and placarding requirements
For instance, when more than one division placard is required for Class 1 materials, only the placard representing the lowest division number must be displayed. A "FLAMMABLE" placard may be used instead of a "COMBUSTIBLE" placard, and a "NON-FLAMMABLE GAS" placard is not required if the transport vehicle is carrying flammable gas or oxygen and displays the correct placards. There are also exceptions for certain hazardous materials covered by Table 2, which are transported by highway or rail, and for certain rail cars loaded with transport vehicles or freight containers.
In the case of diesel fuel, there is often confusion as to whether it is regulated and requires placarding. Diesel fuel is classified as a flammable liquid, but it may be reclassified as a combustible liquid if it has a flashpoint of 38°C (100°F) or above. The placarding requirement is determined by the hazard of the material, the quantity being transported, and the type of packaging used. Diesel in non-bulk packaging (with a capacity of 119 gallons or less) is generally not subject to HMR and does not require a placard. However, when transported in bulk packaging (with a capacity of over 119 gallons), diesel fuel is regulated and does require placarding.
Full diesel loads, for example, cannot carry a 1203 placard and must be marked with an NA 1993 placard. This also applies to multi-compartment tanks transporting diesel.
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Multi-compartment tanks and placarding
Multi-compartment tanks are designed to store multiple grades of products or different types of products in the same tank. They are a safe and economical alternative to installing separate tanks for each product. For instance, diesel and biodiesel blends can be stored in the same tank.
When it comes to placarding requirements for multi-compartment tanks carrying diesel, the regulations can be confusing. The need for placarding depends on several factors, including the hazard level of the material, the quantity being transported, and the type of packaging used.
Diesel fuel is generally classified as a flammable liquid in the hazardous materials table (§172.101). However, if it has a flashpoint at or above 100°F (38°C), it can often be reclassified as a combustible liquid. In such cases, when diesel is transported in non-bulk packaging (with a capacity of 119 gallons or less), it is typically not subject to hazardous materials regulations (HMR), and a placard is not required.
On the other hand, when diesel is transported in bulk packaging (with a capacity greater than 119 gallons), it is regulated and does require placarding. Additionally, a full diesel load in a multi-compartment tank must be marked with the NA 1993 placard, as stated by the PHMSA letter. This interpretation also applies if the multi-compartment tank is transporting only diesel.
It's important to note that there are products like the MultiCube, a multi-tank fuel trailer, that allow for the transportation of diesel fuel without the need for hazmat placarding. This makes it a convenient option for industries such as fuel distribution, rental, and construction.
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Frequently asked questions
Yes, diesel fuel is classified as a flammable liquid, and in most cases, it may be reclassified as a combustible liquid if its flashpoint is at or above 100° F (38° C). The placarding requirement is determined by the hazard of the material, the quantity being transported, and the type of packaging used.
The type of placard required depends on the packaging. For bulk packaging, diesel fuel requires placarding, whereas for non-bulk packaging, a placard is typically not required.
Yes, the Department of Transportation (DOT) has guidelines for dangerous goods marking. Placards must meet the DOT placarding specifications for hazardous materials identification, and federal and local authorities should be consulted for proper use. Additionally, full diesel loads must be marked with the NA 1993 placard instead of the 1203 placard.
