Hazmat Certification Under Placarding Exemption
The US DOT recently issued a “Letter of Interpretation” (LoI) regarding the lack of a need for a driver to have a hazmat (hazardous materials) endorsement on the CDL (Commercial Driver’s License) when transporting Class 9 hazmat within the US, despite the presence of Class 9 placards.
Changing Modes without Removing Placards
This situation is likely to occur when foreign shipments arrive which did not have the equivalent to the US 49 CFR §172.504(f)(9) conditional exception for Class 9 placarding, and are to be transported to their US destination.
An example would be if a Class 9 consignment arrives by vessel, which has placarding in conformance with the IMDG Code, and is picked up for road transport without removing the placards.
Even if the placards are not removed, there is not a requirement for the hazmat-endorsed CDL (equivalent to a TDG training certificate- for readers North of the 49th, metonymically speaking).
Note that, despite the exception for an actual Class 9 placard, §172.504(f)(9) does require bulk packages to be marked with at least the UN number.
Key to the Endorsement Exemption
49 CFR §383.93(b)(4) invokes the need for a hazmat CDL when the definition of hazmat in 383.5 is met. For substances defined as hazardous in 49 U.S. Code §5103(a) and (other than infectious substances/ biotoxins in 42 CFR §73) requiring placards, the CDL endorsement is required.
Thus, for most Continue Reading…