Understanding Placarding For Class 9 Marine Pollutants

The transportation of hazardous materials, or HazMat, is a complex process that requires careful attention to safety regulations. In the context of Class 9 Marine Pollutants, there are specific requirements for placarding and marking that need to be understood and followed. While Class 9 Marine Pollutants are considered hazardous, they may not be as obviously dangerous as other classes of HazMat. The regulations surrounding their transportation involve the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT/PHMSA). Understanding when and how to use placards and markings for Class 9 Marine Pollutants is essential for safe and compliant transportation.

Class 9 Marine Pollutant identification numbers

The identification of a marine pollutant is a mark, not a placard, though it has the same dimensions and visibility requirements as a placard. The display of the Class 9 placard is not required within the US. However, if transporting a bulk packaging, the identification number must be displayed on all four sides of the vehicle unless the identification number displayed on the tote is visible during transport. For instance, the totes are loaded on a flatbed trailer, and the identification number is visible.

The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the US Department of Transportation (USDOT/PHMSA) are especially tricky when the issues of marine pollutants and Class 9 Miscellaneous come up. This is because the rest of the world classifies a marine pollutant differently than in the US, with the rest of the world requiring the display of the Class 9 placard.

A material is identified as a Marine Pollutant (MP) if it is listed in the IMDG Code Index or if it meets the criteria for classification as "Environmentally Hazardous Substance (aquatic environment)". Aquatic toxicity data, degradation data, and BCF data are needed to determine if a material belongs to environmentally hazardous substances or not. If a marine pollutant meets the definition of any hazard class or division as defined in this subchapter, other than Class 9, the class of the material must be determined in accordance with § 173.2a of this subchapter.

The placarding and marking requirements for a motor vehicle transporting a bulk packaging of a marine pollutant in the US are complex. For example, a shipper who offers a hazardous material for transport must determine the hazard class of the material, including "environmentally hazardous substances (aquatic environment)" applicability, assign a proper shipping name, and mark the material according to dangerous goods regulations.

Marine Pollutant marks and placards

The identification of a marine pollutant is a mark, not a placard, though it has the same dimensions and visibility requirements as a placard. The display of the Class 9 Miscellaneous placard is not required within the US. However, if transporting bulk packaging, the identification number must be displayed on all four sides of the vehicle unless the identification number displayed on the tote is visible during transport.

A vehicle that transports a package that is marked as a marine pollutant must display the marine pollutant mark (at the size of a placard) on all four sides. The marine pollutant mark must be placed in association with the hazard warning labels required by subpart E or, in the absence of any labels, in association with the marked proper shipping name.

The marine pollutant mark must be displayed in black lettering on a square-on-point configuration with a white or suitable contrasting background. The symbol (fish and tree) must also be in black. The width of the border forming the square-on-point marking must be at least 2 mm. Each side of the mark must be at least 100 mm (3.9 inches) when measured from the outside of the lines forming the border for marks applied to non-bulk packages.

Domestic vs international regulations

The domestic and international regulations for the classification of marine pollutants and the display of the Class 9 Miscellaneous placard vary significantly. The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the US Department of Transportation (USDOT/PHMSA) are particularly complex when dealing with marine pollutants and Class 9 hazardous materials (HazMat).

Domestic Regulations

In the United States, the display of the Class 9 Miscellaneous placard is generally not required for domestic transportation. However, if transporting bulk packaging, the identification number (e.g., UN3082) must be displayed on all four sides of the vehicle unless the identification number displayed on the tote is clearly visible during transport. A vehicle transporting a packaging marked as a marine pollutant must display the marine pollutant mark, which is the size of a placard, on all four sides. This is outlined in 49 CFR 172.322(c).

Additionally, non-bulk packaging transported on the ground in the US is not subject to regulation as a marine pollutant. The determination of bulk or non-bulk packaging is based on the capacity of individual packaging rather than the gross weight or combined weight of the consignment.

International Regulations

Internationally, the regulations for the classification of marine pollutants and the display of the Class 9 placard may differ from those in the US. It is important to note that the rest of the world classifies marine pollutants differently than the US. As such, a substance that is considered a marine pollutant in the US may not be classified as such internationally when offered for transport.

While specific international regulations are not explicitly mentioned, it is clear that there are differences in how Class 9 marine pollutants are regulated domestically versus internationally. These differences can impact the placarding requirements, with the potential for a Class 9 placard to be unnecessary internationally.

HazMat Requirements

It is worth noting that Class 9 HazMat is vaguely defined and broadly encompasses hazardous goods that do not fit into Classes 1-8. While there are no additional requirements for drivers beyond possessing the necessary licenses and medical cards, complying with regulations is crucial due to the potential harm these materials can cause to humans, property, and the environment.

HazMat shipping paper

The US Department of Transportation has established specific transportation hazard classification criteria for materials based on their chemical and physical properties. It is the shipper's responsibility to correctly classify and package their material with the correct hazard communications (e.g. marks, labels, and shipping documentation).

Hazardous materials regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the US Department of Transportation (USDOT/PHMSA) are especially tricky when the issues of marine pollutants and Class 9 come up. The display of the Class 9 placard and the marine pollutant mark are not always required. However, if transporting a bulk packaging, the identification number must be displayed on all four sides of the vehicle unless the identification number displayed on the tote is visible during transport.

A HazMat shipping paper must contain a description of the HazMat, including the UN identification number, proper shipping name, hazard class, and packing group, quantity, number and type of packages, emergency contact information, and a shipper’s certification. The description of the hazardous material must be included on the shipping paper and conform to the following requirements:

• When a hazardous material and a material not subject to the requirements of this subchapter are described on the same shipping paper, the hazardous material description entries required by § 172.202 and those additional entries that may be required by § 172.203 must be entered in a colour that clearly contrasts with any description on the shipping paper of a material not subject to the requirements.
• Must be identified by the entry of an “X” placed before the basic shipping description required by § 172.202 in a column captioned “HM”.
• A shipping paper may contain additional information concerning the material provided the information is not inconsistent with the required description.

Bulk packaging

The regulations for transporting hazardous materials, including marine pollutants, are complex and vary between countries. In the US, Class 9 hazardous materials are exempt from placarding when transported domestically, regardless of the quantity or packaging. However, if the Class 9 material is a marine pollutant, it must be labelled with a "MARINE POLLUTANT" label of the same size as a placard. This is because, in the event of an accident near a body of water, responders need to be aware that the contents of the vehicle are harmful to the environment.

When it comes to bulk packaging, there are specific requirements for labelling and placarding. Bulk packaging is defined as anything over 1,000 gallons in capacity. In the US, any bulk packaging that contains a Class 9 hazardous material must be labelled with the correct identification number. This can be displayed on a white diamond, an orange panel, or a Class 9 placard on all four sides of the vehicle. If the identification number is visible on the tote during transport (e.g., loaded on a flatbed trailer), then the labelling requirements are met. Additionally, if transporting an elevated temperature material, a "HOT" label must also be included on the packaging.

It is important to note that the marine pollutant mark is only required on a bulk packaging, freight container, or transport vehicle that already bears a HazMat label or placard. The HazMat shipping paper must also include emergency information, and all personnel involved in the transportation must undergo HazMat Employee training.

While Class 9 hazardous materials are exempt from certain regulations, such as the need for a HazMat endorsement and PHMSA registration, it is crucial to comply with the labelling and training requirements to ensure safe transportation and handling.

Frequently asked questions