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What's Wrong with this Picture?: Hazmat Pallet Answers

1. Segregation. The labels on the boxes show three incompatible substances: Flammable Solid, Corrosive, and Dangerous When Wet. See the Segregation Table in §177.848. No person may accept for transportation or transport by motor vehicle any materials that are “forbidden” in the regulations or hazardous materials not prepared in accordance with the regulations. See: §173.30 and §177.801.

2. Leaking box. The lower right-hand box is leaking in the corner. Immediately above, the label indicates that the contents of the box become dangerous if wet. This could be a formula for hazard.

3. Securing cargo. According to §177.834(a), packaging not permanently attached to the transport vehicle must be secured against shifting, including relative motion between packages, within the vehicle on which it is being transported, under conditions normally incident to transportation. Also, the Federal Motor Carrier Safety Regulations (FMCSRs) have general securement requirements (§393.106) that apply to all types of cargo except commodities in bulk that lack structure or fixed shape (e.g., liquids, gases, grain, liquid concrete, sand, gravel, aggregates) and are transported in a tank, hopper, box, or similar device that forms part of the structure of a commercial motor vehicle. Under these general securement rules

: • A commercial motor vehicle is not to be driven unless the load is properly distributed and adequately secured;

• Cargo must be firmly secured using vehicle structures, dunnage, dunnage bags, shoring bars, tiedowns, or a combination of these; and

• Cargo that is likely to roll must be restrained by chocks, wedges, a cradle, or their equivalent.

4. Broken pallet. The front left-hand side of the pallet is broken and protruding. Although pallets are not specifically mentioned in either the FMCSRs or HMR, §393.104(b) prohibits the use of damaged securement devices. A pallet may be categorized as a securement device.

Related information:

Topic Index: Cargo Handling Labeling Segregation Segregation Table

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