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DISCUSSION 2: Loading and Unloading

49 CFR177.834

General Requirements

When any package of hazardous materials is loaded into a vehicle, that package must be secured in the vehicle against movement and relative motion against of other packages. You just can't have them rolling or bouncing around inside the truck. It would seem like common sense, but I guess you just have to write it down to be sure.

When loading or unloading explosives, flammable gas, liquid, or solid, or oxidizing material you may not smoke and must keep all fire away from the vehicle. Common sense?

You must also set the hand brake when loading and unloading hazardous materials. Actually I believe you need to set the handbrake anytime you are out of the vehicle or loading anything. But that is another set of regulations/statutes. California Vehicle Code 22515 for instance.

You should not use tools that might damage the containers of explosives or other dangerous articles.

Although covered in 177.834(a) in general, 177.834(g) states specifically that you must prevent relative motion between containers of explosives, flammable solids or liquids, oxidizers, corrosives, gases, and poison gases or liquids. They must really mean it to say it twice in the same section. But it only makes sense. After rubbing against each other during transportation for a period of time one or both of the packages could be worn through and the contents released. That would not be a good thing.

While in transit, you must prevent undue rise in temperature to the container and its contents. You may not tamper with the container and must ensure that there is no release of the material between the origin of the shipment and its destination.

While loading or unloading a cargo tank a qualified person must be in attendance. That means the person must be specifically trained to operate the tank, be alert and within 25 feet of the tank and have an unobstructed view of the tank and delivery hose.

Now here is one for the books. If you are transporting explosives or flammable material you can not use a cargo heater while in transit. I can't imagine why!

There are more details in that section but just as these appear to be common sense, most of the rest do as well. Read the section in its entirety and you will see.

DISCUSSION 3: Instruction for Specific Hazard Classes

49 CFR177.835 through 843

Once again we are entering the realm of common sense. Most of the regulations for specific hazard classes are just as sensible as the general ones. I do not plan to go into great detail for each class but simply present a synopsis. So lets get to it.

49 CFR177.835

For explosives you must have the motor stopped while loading and unloading. Protect the material from sharp projections as well as from being damaged by other lading. You must also separate the tools for preparing the charge, and the detonators, from the explosives. Sounds like good advice.

49 CFR177.837

For flammable liquids you must stop the motor and ground and bond the truck to prevent static electric discharge. More sage advice.

49 CFR177.838

Flammable solids and oxidizing material must be kept within the body of the vehicle or covered while in transit.

This section also says you must keep Dangerous When Wet materials dry. Now why would you want to do that?

When hauling Spontaneously Combustible materials you should provide adequate ventilation to prevent heat build up and fire.

There are additional requirements for Nitrates, Smokeless Powder, and Pyrophoric materials. But, like I said, I am not going to cover every detail. Your job in this course is to learn how to find stuff, not how to memorize everything that is in 49 CFR.

49 CFR177.839

Corrosive Material. One of the biggies here is that Nitric Acid may not be stacked above any other material.

Also, when you load car batteries, you want to make sure that nothing shorts the terminals. Makes sense to me.

49 CFR177.840

The loading of cylinders has some interesting stuff. First off the floor of the vehicle must be essentially flat. (Please don't ask, I don't know). Cylinders must be lashed up right, loaded in racks, packed in boxes or crates, or loaded horizontally.

When loading or unloading the engine must be off except for the transfer pump if it is being used.

For loads of chlorine, a protective mask and leak kit are required while in transit (which includes loading and unloading).

Before unloading a cargo tank of liquified compressed gas, the qualified person must inspect the discharge system.

If there is an unintentional release of product to the environment, the qualified person must immediately shut down the internal shut off valve and all motive and power equipment.

There is another page or two of directions for cylinders but you can read those if you wish.

49 CFR177.841

More interesting stuff for transporting poisons. If you are transporting poison in a cargo tank, all the hatches and valves must be closed and secured and leak free. They would not have to tell me twice.

You may not transport poisons with human or animal food unless overpacked in a liquid tight and dustproof container.

Here's a good one. You may not transport poison gas, liquid, or solid in the cab of the thr truck. Again, you would not have to remind me of that.

There are several more items in these sections but I think you have the point. When you get ready to transport some HazMat be sure to review the section(s) for your specific hazard class before you hit the road.

ACTION:

You should still have your Student Guide open to Chapter 9 Loading. We will be on page 9-12, paragraph C "Segregation of Hazardous Materials". Your 49 CFR should be open to 49 CFR177.848. You will see a table there and that is where we are going to spend some time. When you find the table go on to the discussion below.

DISCUSSION 4: Segregation of Hazardous Material

49 CFR177.848

If you look at 49 CFR177.848(e) you will find the instruction for using this table. But I will take a few minutes to explain it in English (as opposed to Federalese).

The intent of this table is to guide you in determining what Hazardous Materials may be loaded together in the same vehicle. It also refers to storing them together while in transit. And it is pretty straight forward. But first, lets look at what is meant by the "same vehicle". If you are pulling two trailers with a single truck (a set of doubles) each trailer constitutes a separate vehcile. That is why it is called a combination of vehicles. So if something is prohibited from being loaded on the same vehicle it may be loaded on the other trailer. Now on to the table.

The first thing you do with this table is find one of the hazard classes you plan to load in the column on the left. Find the other hazard class in the row across the top. Then find where they intersect.

If there is no entry at the intersection, there are no restricitions on loading those two materials together on the same vehicle.

Lets try that out by doing the Practice 4a on the right.

PRACTICE 4a:

You are shipping Flammable Solids 4.1 and want to put them on the same vehicle with Flammable Liquids 3. Can you do that?

RESULT 4a:

If you find a "O" at the intersection of your two hazard classes then you may not load them on the same vehicle unless separated in a manner that would prevent "commingling" of the materials. Now do Practice 4b to test that theory.

PRACTICE 4b:

You are shipping Poison Gas Zone B 2.3 and want to put them on the same vehicle with Flammable Liquids 3. Can you do that?

RESULT 4b:

If you find a "X" at the intersection of your two hazard classes then you may not load them on the same vehicle. Now do Practice 4c to see how this pans out.

PRACTICE 4c:

You are shipping Poison Liquid, PG I, Zone A 6.1 and want to put them on the same vehicle with corrosive Liquids 8. Can you do that?

RESULT 4c:

DISCUSSION 4: Segregation of Hazardous Material (continued)

49 CFR177.848(c)

If you look at 49 CFR177.848(c) you will find some information about transporting Cyanide and its mixtures. You can not transport them with acids if the mix would produce hydrogen cyanide gas. That's the same stuff used in the gas chamber at San Quentin. Drop some potassium cyanide into sulfuric acid and bingo, hydrogen cyanide gas. Very lethal. So don't load you car batteries in the same truck with cyanide stuff.

That same section says you can not load or transport 4.2 (Spontaneously Combustible) with 8 (Corrosive Liquids).

49 CFR177.870

This section regulates the carrying of HazMat on passenger carrying vehicles. Basically it prohibits all but small arms ammunition (the military may carry more substantial munitions of war where no other reasonable alternative is available) and puts restrictions on other hazard classes. This applies primarily to vehicles carrying passengers for hire.

As you can see, you may not just pitch all your HazMat on the truck and scurry down the road. You need to do some research first and then comply with the HMR.

Now go on to the next discussion to see how to load explosives.

DISCUSSION 4: Segregation of Hazardous Material (continued some more)

49 CFR177.848

Notice in the table that when you cross reference two explosives you only find an "*". While you can determine whether you can load explosives with other hazard classes, you can not determine which explosives may be loaded together with this chart. For that you must refer to the "Compatibility Table for Class 1 (Explosive) Materials" in 49 CFR177.848(f). You look in 49 CFR177.848(g) for instructions on the use of this table.

First off you must know the "Compatibility Group Letter" of the explosive. That will be in column 3 of the HMT next to the "Proper Shipping Name" of the explosive you wish to ship.

Once you find the "Compatibility Group Letter" of the explosives that you want to ship together you locate one of the letters in the first column of the table and the second one in the list across the top. Then go to where they intersect to see what letter or number is there.

If you look in 49 CFR177.848(g)(2) you will see that when an "X" is found at the intersection that you can not load those explosives on the same transport vehicle.

If you find a number then read the notes below the table in 49 CFR177.848(g)(3). For instance note "2" means that combinations of Compatibility Groups C, D, or E are all assigned to Group E. Note "3" means that combinations of Groups C, D, and E, with Group N is assigned to Group D. Ain't this a hoot. Just read the notes if you ever transport or offer explosives for transportation.

To find out what all those "Compatibility Group Letters" really mean go to 49 CFR173.52 and there is a table there, "Table 1 - Classification Codes".

If you find no entry at the intersection that is because it is the intersection of the same "Compatibility Group Letters" and of course you can load those together on the same vehicle.

ACTION:

Well that should tide you over for a while. Now take a bit of a breather before beginning the next session.

RESULT 4a:

It is blank where 4.1 and 3 intersect so you may load them on the same vehicle.

RESULT 4b:

Where Posion Gas Zone B 2.3 and 3 intersect is a "O"so you may load them on the same vehicle as long as you separate them to prevent commingling of materials.

RESULT 4c:

Where Posion Liquid, PG I, Zone A 6.1 and 8 intersect is an "X"so you may not load them on the same vehicle.