Regulation

173.150

Regulation summary

Section 173.150 establishes limited quantity exceptions for Class 3 and combustible liquids. Limited quantities of flammable liquids and combustible liquids are excepted from labeling requirements, unless the material is offered for transportation by aircraft, and are excepted from the specification packaging requirements.

Question/Dilemma

A carrier may receive a full trailer of limited quantity Class 3 material with an aggregate weight of approximately 40,000 pounds. The carrier inquires if the trailer should be placarded and if the driver is required to have any type of hazardous materials license or permit.

In this interpretation, PHMSA addresses placards and CDL hazardous materials endorsements.

Interpretation summary

In interpretation Ref. No. 14-0231, PHMSA advises that Class 3 materials offered under the limited quantity exceptions provided in 173.150 are not non-hazardous products. If a shipment is under the quantity thresholds and is appropriately offered as a limited quantity, then it is eligible for exceptions from various hazardous materials requirements (e.g., specification packaging, labeling, placarding, and shipping papers).

• Class 3 limited quantity shipments are excepted from placarding requirements even if the aggregate weight is 40,000 pounds.

PHMSA advises drivers of vehicles transporting hazardous materials that are required to be placarded in accordance with Subpart F of Part 172 of the HMR must have a commercial driver’s license (CDL) with a hazardous materials endorsement.

• A hazardous materials endorsement is not required for a driver of a transport vehicle which contains only limited quantities.