Hazmat Placard Requirements in the US
When are hazmat placards required in the US?
Short answer: Under 49 CFR 172.504(a), placards are required on each side and each end of every bulk packaging, freight container, unit load device, transport vehicle or rail car that contains any quantity of a hazardous material, unless the subchapter provides an exception. How much material it takes depends on which table the hazard class is in. Table 1 materials need placards at any quantity. Table 2 materials moving by highway or rail need placards only once the vehicle or container holds 454 kg (1,001 lb) or more aggregate gross weight, and bulk packagings get no such exception.
Approach: The only US DOT text in the datasets is the 49 CFR 172.101 Hazardous Materials Table, so I read the current eCFR text of 49 CFR Part 172 Subpart F (§§ 172.500, 172.504, 172.505, 172.514) directly.
1. Who and what is covered (§ 172.500)
Each person who offers or transports a hazardous material "shall comply" with the placarding requirements. The placarding subpart does not apply to:
- infectious substances;
- limited quantities, when identified on the shipping paper under § 172.203(b) or marked under § 172.315;
- materials prepared under § 173.13;
- small quantities under §§ 173.4, 173.4a and 173.4b;
- combustible liquids in non-bulk packagings.
2. Table 1: placard at any quantity
| Class/division | Placard |
|---|---|
| 1.1, 1.2, 1.3 | EXPLOSIVES 1.1 / 1.2 / 1.3 |
| 2.3 | POISON GAS |
| 4.3 | DANGEROUS WHEN WET |
| 5.2 (Organic peroxide Type B, liquid or solid, temperature controlled) | ORGANIC PEROXIDE |
| 6.1 (poisonous by inhalation) | POISON INHALATION HAZARD |
| 7 (Radioactive Yellow III label only) | RADIOACTIVE |
RADIOACTIVE placards are also required for:
- all shipments of unpackaged LSA-I material or SCO-I;
- exclusive-use shipments required by §§ 173.427, 173.441 and 173.457;
- closed vehicles used under § 173.443(d).
3. Table 2: the 1,001 lb threshold
Table 2 covers these classes:
- 1.4, 1.5, 1.6
- 2.1 FLAMMABLE GAS and 2.2 NON-FLAMMABLE GAS
- 3 FLAMMABLE, and combustible liquid (COMBUSTIBLE placard)
- 4.1 FLAMMABLE SOLID and 4.2 SPONTANEOUSLY COMBUSTIBLE
- 5.1 OXIDIZER, and 5.2 other than Type B temperature controlled (ORGANIC PEROXIDE)
- 6.1 other than inhalation hazard (POISON)
- 6.2 (no placard: NONE)
- 8 CORROSIVE
- 9 CLASS 9
Exception in § 172.504(c): By highway or rail, placards are not required on a transport vehicle or freight container holding less than 454 kg (1,001 lb) aggregate gross weight of Table 2 materials. Nor are they required on a rail car loaded only with vehicles or containers that themselves need no placards. This exception does not cover:
- bulk packagings;
- materials subject to § 172.505.
You may still display placards voluntarily below the threshold, unless § 172.502 prohibits it.
DANGEROUS placard (§ 172.504(b)): If non-bulk packages carry two or more Table 2 categories, you "may" use a DANGEROUS placard instead. Once 1,000 kg (2,205 lb) or more aggregate gross weight of one category is loaded at one loading facility, that category's own placard "must be applied".
Empty packagings (§ 172.504(d)):
- Non-bulk packagings holding only residue of a Table 2 material need not be counted.
- Vehicles carrying empty IBCs under § 173.29(d) are not subject to placarding.
4. Subsidiary-hazard placards (§ 172.505), required on top of § 172.504
- Poison inhalation hazard: POISON INHALATION HAZARD or POISON GAS placards on each side and each end. This applies to vehicles, freight containers, portable tanks, unit load devices and rail cars.
- Dangerous when wet subsidiary hazard: DANGEROUS WHEN WET placards on each side and each end.
- Uranium hexafluoride: 454 kg (1,001 lb) or more gross weight requires CORROSIVE and POISON placards, in addition to any RADIOACTIVE placard.
5. Bulk packagings (§ 172.514)
- The offeror "shall affix" the § 172.504/172.505 placards.
- Placards must stay on after emptying unless the packaging:
- is cleaned and purged of residue and vapours;
- is refilled so that any remaining residue is no longer hazardous;
- holds only a Class 9 hazardous-substance residue below the reportable quantity and conforms to § 173.29(b)(1);
- is an empty IBC moved under § 173.29(d).
- The following may be placarded on only two opposite sides, or labelled instead:
- portable tanks under 3,785 L (1,000 gal);
- DOT 106/110 multi-unit tank car tanks;
- other bulk packagings (for example bags or boxes, but not portable tanks, cargo tanks, flexible bulk containers or tank cars) under 18 m³ (640 ft³);
- IBCs;
- Large Packagings.
- Flexible bulk containers may be placarded in two opposing positions.
6. Other exceptions in § 172.504(f)
- Class 9: No CLASS 9 placard is required for domestic transport, including the US portion of an international move. A bulk packaging must still show its ID number on a CLASS 9 placard, an orange panel or a white square-on-point display.
- Class 1 divisions: Only the lowest division's placard must be displayed.
- Combinations where one placard is enough:
- NON-FLAMMABLE GAS is not required if the vehicle is placarded FLAMMABLE GAS or OXYGEN.
- OXIDIZER is not required alongside EXPLOSIVES 1.1/1.2 placards, or (road/rail only) alongside EXPLOSIVES 1.5 placards.
- For domestic transport, POISON INHALATION HAZARD is not required on a vehicle or container already placarded POISON GAS.
- For domestic transport, POISON is not required where a POISON INHALATION HAZARD or POISON GAS placard is required.
- Optional substitutions:
- FLAMMABLE may replace COMBUSTIBLE on cargo or portable tanks, and on compartmented tank cars holding both flammable and combustible liquids.
- OXYGEN may replace NON-FLAMMABLE GAS for domestic oxygen (compressed or refrigerated liquid).
- The POISON placard for 6.1 PG III materials may show "PG III".
- 1.4S: No EXPLOSIVE 1.4 placard is needed for 1.4S materials that are not required to be labelled 1.4S.
For Class 1 by aircraft or vessel, § 172.504(g) requires the compatibility group letter to appear on the placards.
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What do the different placards mean?
A US hazmat placard tells you the hazard class or division of what's in the vehicle or container. You read it from the class or division number in the bottom corner, the background colour and, usually, a word such as FLAMMABLE or POISON. 49 CFR 172.519 says the number "must be displayed in the lower corner". It also says hazard text "is not required" on any placard except the Class 7 (RADIOACTIVE) and DANGEROUS placards. On the OXYGEN placard the text can be left off only if the identification number is shown instead.
Approach: The only US DOT text in the datasets is the § 172.101 Hazardous Materials Table, so I read the current eCFR text of 49 CFR 172.519 to 172.560 (placard specifications) and 49 CFR 173.2 (hazard class index). The regulation shows each symbol only as a drawing, so I haven't described the symbols in words.
What each placard means and how to recognise it
The meaning is the class or division name from 49 CFR 173.2. The design is from the placard's own section.
| Placard (section) | Class / division and meaning (§ 173.2) | Colours required |
|---|---|---|
| EXPLOSIVES 1.1, 1.2, 1.3 (§ 172.522) | 1.1: mass explosion hazard; 1.2: projection hazard; 1.3: mainly a fire hazard | Orange background; black symbol, text, numerals and border. The "*" is replaced by the division number and, when required, the compatibility group letter |
| EXPLOSIVES 1.4 (§ 172.523) | 1.4: no significant blast hazard | Orange; black text; "1.4" at least 64 mm high |
| EXPLOSIVES 1.5 (§ 172.524) | 1.5: very insensitive explosives; blasting agents | Orange; black text; "1.5" at least 64 mm high |
| EXPLOSIVES 1.6 (§ 172.525) | 1.6: extremely insensitive detonating substances | Orange; black text; "1.6" at least 64 mm high |
| FLAMMABLE GAS (§ 172.532) | 2.1: flammable gas | Red; white symbol, text and number |
| NON-FLAMMABLE GAS (§ 172.528) | 2.2: non-flammable compressed gas | Green; white symbol, text and number |
| OXYGEN (§ 172.530) | Oxygen; used in place of NON-FLAMMABLE GAS (see note 1) | Yellow; black symbol, text and number |
| POISON GAS (§ 172.540) | 2.3: poisonous gas | White, with a black upper diamond; black text and number |
| FLAMMABLE (§ 172.542) | 3: flammable liquid | Red; white symbol, text and number. "GASOLINE" may replace "FLAMMABLE" on cargo or portable tanks carrying gasoline by highway |
| COMBUSTIBLE (§ 172.544) | 3: combustible liquid | Red; white symbol, text and number. "FUEL OIL" may replace "COMBUSTIBLE" on cargo or portable tanks carrying fuel oil (not classed flammable) by highway |
| FLAMMABLE SOLID (§ 172.546) | 4.1: flammable solid | White with seven vertical red stripes; black symbol, text and number |
| SPONTANEOUSLY COMBUSTIBLE (§ 172.547) | 4.2: spontaneously combustible material | White upper half, red lower half; black symbol, text and number |
| DANGEROUS WHEN WET (§ 172.548) | 4.3: dangerous when wet material | Blue; white symbol, text and number |
| OXIDIZER (§ 172.550) | 5.1: oxidizer | Yellow; black symbol, text and division number |
| ORGANIC PEROXIDE (§ 172.552) | 5.2: organic peroxide | Red top half, yellow lower half; black text and number; the symbol may be black or white |
| POISON (§ 172.554) | 6.1: poisonous materials | White; black symbol, text and number. "TOXIC" may be used instead of "POISON" |
| POISON INHALATION HAZARD (§ 172.555) | 6.1 poisonous by inhalation (see note 2) | White, with a black upper diamond; black text and number |
| RADIOACTIVE (§ 172.556) | 7: radioactive material | Yellow triangle in the upper part, white below; black trefoil symbol, text and number |
| CORROSIVE (§ 172.558) | 8: corrosive material | White triangle in the upper part, black below; white text and number; black symbol |
| CLASS 9 (§ 172.560) | 9: miscellaneous hazardous material | White, with seven black vertical stripes on the top half; the class number 9 underlined and centred at the bottom |
| DANGEROUS (§ 172.521) | Mixed load of two or more Table 2 categories in non-bulk packages (§ 172.504(b), see the earlier answer) | Red upper and lower triangles; white centre and border; black inscription |
Notes to the table:
- Under § 172.504(f), covered in the earlier answer, OXYGEN may replace NON-FLAMMABLE GAS for domestic oxygen, compressed or refrigerated liquid.
- Under § 172.505, also covered earlier, this placard is required on top of the primary placard.
- Division 6.2 (infectious substance) is listed in § 173.2, but it has no placard because placarding does not apply to infectious substances (§ 172.500).
Design rules common to all placards (§ 172.519)
- Shape and size: a diamond (square on point) at least 250 mm (9.84 in) per side. It must have a solid inner border about 12.5 mm inside the edge.
- Lettering: class or division numbers, and any hazard text, at least 41 mm (1.6 in) high unless a placard's own section says otherwise.
- Colour: colours must fall within the DOT Hazardous Materials Label and Placard Color Tolerance Chart. The PANTONE formula guide may be used as an alternative.
- Durability: colours must survive a 72-hour fadeometer test and 30 days of open weather.
- International shipments: for shipments under 49 CFR Part 171 Subpart C, placards meeting the UN Recommendations, ICAO Technical Instructions, IMDG Code or Transport Canada TDG Regulations "may" be used. Loads containing a material poisonous by inhalation are the exception: they must be placarded to the DOT specifications.
- Rail and highway route controlled quantity loads: some rail-car placards (§ 172.510(a)), and placards on motor vehicles carrying highway route controlled quantity radioactive material (§ 172.507), sit on a square background. The background is a white square of 14¼ in (362 mm) with a black border out to 15¼ in (387 mm) (§ 172.527).
Each class has a full legal definition in the Part 173 section listed in § 173.2, for example § 173.120 for Class 3 and § 173.136 for Class 8. I can pull any of them if you need the classification criteria.
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How are placards different from labels?
Labels go on individual packages. Placards go on the bulk packaging, freight container, vehicle or rail car that carries them. Under 49 CFR 172.400(a), each non-bulk package and each smaller bulk unit "must" be labelled. Larger units are placarded under Part 172 Subpart F (§ 172.504). The two systems use the same hazard classes and the same diamond design, but they differ in size, where they go, what triggers them and how subsidiary hazards are shown.
Approach: The only US DOT text in the datasets is the § 172.101 Hazardous Materials Table, so I read the current eCFR labelling sections (§§ 172.400, 172.400a, 172.402, 172.406, 172.407). I compared them with the placarding sections covered in the earlier answers.
Side-by-side
| Labels (Part 172 Subpart E) | Placards (Part 172 Subpart F) | |
|---|---|---|
| Goes on | Non-bulk packages, plus some smaller units (see note 1) (§ 172.400(a)) | Each side and each end of bulk packagings, freight containers, unit load devices, transport vehicles and rail cars (§ 172.504(a)) |
| Minimum size | Diamond at least 100 mm (3.9 in) per side, with a 5 mm inner border. The size may be reduced proportionally if the symbol and other elements stay clearly visible (§ 172.407) | Diamond at least 250 mm (9.84 in) per side, with a border about 12.5 mm inside the edge (§ 172.519) |
| Class number | "Must be displayed in the lower corner" of primary and subsidiary labels, 6.3 to 12.7 mm high (§§ 172.402(b), 172.407) | In the lower corner, at least 41 mm high unless the placard's own section says otherwise (§ 172.519) |
| Weight threshold | No aggregate-weight threshold in § 172.400: each package bears its labels | Table 2 materials by highway or rail need no placard below 454 kg (1,001 lb) aggregate gross weight, except in bulk packagings (§ 172.504(c)) |
| Subsidiary hazards | Primary and subsidiary labels as listed in column 6 of the § 172.101 Table (§ 172.402(a)). They must be displayed within 150 mm (6 in) of one another (§ 172.406) | Mostly the primary hazard only. Subsidiary placards are required only for poison inhalation hazard, dangerous when wet and uranium hexafluoride (§ 172.505) |
| Mixed loads | Each package carries its own labels | The DANGEROUS placard may be used for mixed Table 2 loads (§ 172.504(b)) |
| Durability | Must survive a 30-day exposure to conditions of transport and a 72-hour fadeometer test (§ 172.407) | Must survive a 72-hour fadeometer test and 30 days of open weather (§ 172.519) |
Notes to the table:
- The smaller units are: bulk packaging under 18 m³ (640 ft³); portable tanks under 3,785 L; DOT 106/110 multi-unit tank cars; and overpacks or freight containers under 18 m³. Each needs labels only if it is not placarded.
- Placards are covered by §§ 172.504 to 172.505.
Where the two systems overlap
- Small bulk units: labels are an alternative to placards. § 172.400(a) requires labels on these units unless they are placarded. § 172.514 lets the same kinds of units be labelled instead of placarded.
- Placarded containers: § 172.400a exempts freight containers and unit load devices that are placarded from labelling.
- Overpacks: labels need not be repeated on an overpack or unit load device when the package labels remain visible (§ 172.400a).
Things only labels have
- Division 6.2 INFECTIOUS SUBSTANCE label (§ 172.432): there is no infectious-substance placard, because placarding does not apply to infectious substances (§ 172.500).
- Class 7 label variants and FISSILE and EMPTY labels (§§ 172.436 to 172.450): the Radioactive Yellow III label is what triggers the RADIOACTIVE placard under Table 1.
- CARGO AIRCRAFT ONLY label: a person offering or transporting by air hazmat that is authorised on cargo aircraft only "shall label the package" with it (§ 172.402(c)). It must be at least 110 × 120 mm (§ 172.407).
- Placement rules for packages (§ 172.406):
- not on the bottom surface;
- for air transport, the entire label must appear on one side of the package;
- duplicate labels on two sides for packages of 1.8 m³ or more and for non-bulk radioactive packages;
- a label "may not be obscured by markings or attachments".
Exceptions that differ
Labelling exceptions (§ 172.400a):
- certain Dewar flasks and cylinders;
- cylinders permanently mounted on vehicles;
- some military shipments;
- toy caps;
- some subsidiary labels: no 6.1 label on Class 8 materials whose toxicity comes only from corrosive action, and no 4.1 label on Division 4.2 packages.
Placarding exceptions (§ 172.500): placarding does not apply to limited quantities, small quantities, infectious substances or combustible liquids in non-bulk packagings.
To find which labels a specific material needs, look up its § 172.101 Table entry (column 6 gives the label codes). I can pull that for any proper shipping name or UN number.
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