January 15, 2021: Beware of the TOP TEN Hazmat Violations! (Part I)

FMCSA’s Motor Carrier Management Information System (MCMIS) identified the “Top 10 Hazardous Materials Violations” as of October 30, 2020. We’ll begin Part I of our countdown this week and round out the list in Part II next week. Let’s address the violation and the requirements necessary to comply with the regulations.

10. Offer or transport without emergency response information [49 CFR 172.600(c)]. The requirement for emergency response information is applicable to offerors, carriers and anyone who handles hazardous materials during transportation.

At a minimum, emergency response information must include the following seven elements:

  1. The basic description and technical name of the hazardous
  2. Immediate hazards to health;
  3. Risks of fire or explosion;
  4. Immediate precautions to be taken in the event of an accident or incident;
  5. Immediate methods for handling fires;
  6. Initial methods for handling spills or leaks in the absence of fire; and
  7. Preliminary first aid measures

9.  Prohibited placarding [49 CFR 172.502(a)(1)]. Placards are permissible only if hazardous
materials are present, and the placards represent the actual hazard(s) of the material. In other   words, you must ensure the correct placards are displayed, or in the case of an empty vehicle, rail car or other shipping device (e.g., an IBC), the placards are removed. It is illegal to display a placard if the hazard it represents is not present.

8.  Placard damaged, deteriorated, or destroyed [49 CFR 172.516(c)(6)]. Placards must be maintained by the carrier in a condition so that the format, legibility, color, and visibility of the placard will not be substantially reduced due to damage, deterioration, or obscurement by dirt or other matter. A quick walk-around to observe the conditions of the placards should do the trick. If there is any doubt, err on the side of being conservative and replace the placard.

7.  Accessibility of emergency response information [49 CFR 172.602(c)(1)]. The emergency response information must be available immediately to:

  • Federal and State Agency authorities,
  • Emergency responders; and
  • Officials conducting an investigation.

6.  No placards/markings when required [49 CFR 177.823(a)]. A carrier may not move a transport vehicle containing a hazardous material unless the vehicle is marked and placarded in accordance with part 172.

The placarding requirements are in Subpart F and include rules for applicability, prohibitive and permissive placarding, general requirements, subsidiary hazards and more.

The marking requirements can be found in Subpart D and include mandates for portable tanks, cargo tanks, tank cars, multi-unit tank car tanks, and other non-bulk packages.

What can STARS do for you?

We can help you:

  • Develop emergency response information for each of the materials you ship offsite.
  • Put together a placarding program for each type of shipping device. We can make visual quick reference guides for your employees.
  • Create completeness checklists to ensure full compliance before a vehicle leaves your premises.

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