Hazmat placard requirements: the 1,001-pound rule and the two tables

A truck needs hazmat placards on each side and each end if it carries any quantity of a material in Table 1 of 49 CFR 172.504 (for example explosives 1.1 to 1.3 or poison gas), if it carries 1,001 pounds or more aggregate gross weight of materials in Table 2 (for example flammable liquids, corrosives or non-flammable gases), or if the hazmat is in a bulk packaging such as a cargo tank. Below 1,001 pounds of Table 2 materials in non-bulk packages, placards are not required, although they are still allowed.

This page explains the two tables, the 1,001-pound calculation, the DANGEROUS placard, the exceptions that take a load out of placarding altogether, and the identification number rules. For what can and cannot share a trailer, see the segregation table guide; for the training every hazmat employee needs, see HazMat employee training.

Who the placarding rules apply to

Section 172.500(a): each person who offers hazmat for transportation, and each person who transports it, must comply with the placarding subpart. The duty is shared. Under 172.506(a) the shipper offering hazmat to a motor carrier must provide the required placards at or before the time it offers the material, unless the truck is already correctly placarded, and under 172.506(a)(1) no motor carrier may transport hazmat unless the required placards are affixed. 177.823(a) repeats the carrier side: a transport vehicle containing hazmat may not be moved unless it is marked and placarded, except in narrow emergency situations.

The basic rule: each side and each end

172.504(a): each bulk packaging, freight container, unit load device, transport vehicle or rail car containing any quantity of hazmat must be placarded on each side and each end with the placards named in Tables 1 and 2. Everything else on this page is an exception or a detail of that sentence.

Table 1: placard for any quantity

The Table 1 materials get no weight threshold. One package on the truck means placards.

Source: Table 1 to 172.504(e). A note to the table also requires RADIOACTIVE placards for certain other radioactive shipments, such as exclusive-use shipments.

Table 2: placard at 1,001 pounds

Source: Table 2 to 172.504(e).

The 1,001-pound rule, exactly

The rule is written as an exception. 172.504(c)(1): except for bulk packagings and materials subject to 172.505, when Table 2 materials are transported by highway or rail, placards are not required on a transport vehicle or freight container that contains less than 454 kg (1,001 pounds) aggregate gross weight of Table 2 hazardous materials. Four points follow from the wording:

• Aggregate. You add up all Table 2 materials on the vehicle, across classes. 600 pounds of Class 3 and 500 pounds of Class 8 is 1,100 pounds of Table 2 material, and the truck must be placarded even though neither class alone reaches 1,001.
• Gross weight. It is the weight of the packages, packaging included, not the net weight of the material inside.
• Table 2 only. Table 1 materials never benefit from this exception.
• Not for bulk. A bulk packaging (a cargo tank, a portable tank, a large IBC) is placarded whatever the quantity.

The same paragraph ends with a permission: the exception does not prohibit placarding a vehicle that is not required to be placarded, if the placards are correct. 172.502(c) says the same thing: placards may be displayed even when not required, provided they conform. What is prohibited (172.502(a)) is a placard for material that is not hazmat, a placard that does not represent the hazard on board, or a sign that could be confused with a placard.

172.504(d)(1) adds that a non-bulk package containing only the residue of a Table 2 material need not be counted. Bulk packagings are different: under 172.514(b) a placarded bulk packaging stays placarded when emptied, until it is cleaned and purged, refilled with something that no longer leaves a hazardous residue, or meets one of the other listed conditions.

The DANGEROUS placard

172.504(b): a vehicle carrying non-bulk packages of two or more categories of Table 2 materials that would need different placards may display a DANGEROUS placard instead of the separate placards. The limit: when 1,000 kg (2,205 pounds) aggregate gross weight or more of one category is loaded at one loading facility, the specific Table 2 placard for that category must be applied. DANGEROUS is never a substitute for a Table 1 placard, because the option only covers Table 2 materials. Under 172.334(a) an identification number may not be displayed on a DANGEROUS placard.

Exceptions that remove placarding entirely

172.500(b) takes five kinds of shipment out of the placarding subpart:

1. infectious substances;
2. hazmat offered as a limited quantity when identified as such on the shipping paper or marked as such;
3. materials prepared under 173.13;
4. materials packaged as small quantities under 173.4, 173.4a or 173.4b; and
5. combustible liquids in non-bulk packagings.

Other exceptions in 172.504(f) that drivers meet often:

• Class 9: a CLASS 9 placard is not required for domestic transportation. A bulk packaging must still show the identification number, on a CLASS 9 placard, an orange panel or a white square-on-point (172.504(f)(9)).
• Several explosive divisions: only the placard for the lowest division number is displayed (172.504(f)(1)).
• FLAMMABLE for COMBUSTIBLE: a FLAMMABLE placard may be used instead of COMBUSTIBLE on a cargo tank or portable tank (172.504(f)(2)).
• Non-flammable gas with flammable gas: NON-FLAMMABLE GAS is not required if the vehicle also carries flammable gas or oxygen and shows FLAMMABLE GAS or OXYGEN placards (172.504(f)(3)).
• OXYGEN: for domestic shipments of compressed or refrigerated liquid oxygen, the OXYGEN placard may replace NON-FLAMMABLE GAS (172.504(f)(7)).
• 1.4S: the EXPLOSIVES 1.4 placard is not required for 1.4S materials that are not required to be labeled 1.4S (172.504(f)(6)).

Subsidiary hazards

172.505 adds placards on top of the primary one in three cases: a material subject to the "Poison Inhalation Hazard" shipping description needs POISON INHALATION HAZARD or POISON GAS placards in addition (172.505(a)); 1,001 pounds or more of uranium hexafluoride needs CORROSIVE and POISON placards in addition to RADIOACTIVE (172.505(b)); and a material with a dangerous when wet subsidiary hazard needs DANGEROUS WHEN WET placards in addition (172.505(c)). Other subsidiary placards are optional (172.505(d)). Because 172.504(c) excludes "hazardous materials subject to 172.505", the 1,001-pound exception does not apply to them.

Where and how placards go on the truck

172.516 sets the display rules:

• clearly visible from the direction each faces (except toward a coupled vehicle); placards on containers or portable tanks can satisfy this (172.516(a));
• the front placard may be on the front of the tractor instead of or in addition to the front of the cargo body (172.516(b));
• securely attached or in a holder, clear of ladders, pipes, doors and tarps, and where practicable away from wheel spray (172.516(c)(1) to (3));
• at least 3 inches from other markings such as advertising (172.516(c)(4));
• words or ID numbers horizontal, reading left to right (172.516(c)(5));
• kept legible and not obscured by damage or dirt (172.516(c)(6)); and
• on a contrasting background or with a contrasting outer border (172.516(c)(7)).

172.519(c)(1): each diamond placard must be at least 250 mm (9.84 inches) on each side, with a solid inner border about 12.5 mm inside the edge. The class or division number in the bottom corner must be at least 41 mm (1.6 inches) high (172.519(c)(2)). A placard must survive 30 days of open weather (172.519(a)(1)). Except for Class 7 and DANGEROUS, the hazard text such as "FLAMMABLE" is not required (172.519(b)(3)).

Identification numbers on placards and panels

The four-digit UN or NA number is a marking, not a placard, but it often goes on or next to one. 172.332 allows it on an orange panel (160 by 400 mm) or across the center of the placard on a white background, and 172.336(b) allows a plain white square-on-point. Limits in 172.334:

• never on RADIOACTIVE, EXPLOSIVES, DANGEROUS or subsidiary placards (172.334(a));
• only on a placard for the material’s primary hazard class, and only if the vehicle actually contains that material (172.332(c)(3), 172.334(b));
• a placard with an ID number cannot cover other materials of the same class unless the number is correct for all of them (172.334(d)).

When are ID numbers required on the vehicle? For bulk packagings, under the marking rules in Subpart D. For non-bulk loads, 172.301(a)(3) requires the ID number on each side and each end when a vehicle carries only one hazmat, every package has the same name and number, the aggregate gross weight is 4,000 kg (8,820 pounds) or more, all of it was loaded at one facility, and nothing else is on the vehicle. That rule does not apply to Class 1 or Class 7. A cargo tank carrying only gasoline or only fuel oil may be marked "Gasoline" or "Fuel Oil" instead of showing the number, under the conditions in the table to 172.336(c).

Placard numbers drivers ask about

Always read the class from the shipping paper, which takes it from the 172.101 Table for the exact entry. The same number can appear on more than one entry.

Labels vs placards

Labels go on packages: under 172.400(a) the offeror labels each non-bulk package, and smaller bulk packagings that are not placarded. Placards go on the vehicle or bulk container. A box of paint in a van has a FLAMMABLE label; whether the van needs FLAMMABLE placards depends on the tables and weights above. A load can be fully labeled and still correctly unplacarded because it is under 1,001 pounds of Table 2 material.

Why placards matter for your license

Under 383.5, a vehicle of any size used to transport hazardous materials, defined as material required to be placarded under Part 172 Subpart F (or any quantity of a listed select agent or toxin), is a commercial motor vehicle (Group C). The driver then needs a CDL with the hazardous materials (H) endorsement (383.93(b)(4)). An unplacarded load under 1,001 pounds of Table 2 material does not by itself create that requirement. How to get the endorsement is covered on the hazmat endorsement page.

Worked examples

Example 1, applying 172.504(c). A box truck carries 700 pounds gross of Class 3 paint in cans and 250 pounds gross of Class 8 cleaner. Total Table 2 material: 950 pounds. That is less than 1,001, nothing is bulk, and nothing is Table 1, so placards are not required. The driver may still display correct FLAMMABLE and CORROSIVE placards under 172.502(c).

Example 2, applying 172.504(b). The same truck picks up another 200 pounds of Class 3 at a second stop. Total: 1,150 pounds, so placarding is now required on each side and each end. The load has two Table 2 categories in non-bulk packages, and no single category reaches 2,205 pounds from one facility, so the driver may use DANGEROUS placards instead of FLAMMABLE and CORROSIVE.

Example 3, applying Table 1. A pickup carries one 20-pound cylinder of a Division 2.3 poison gas. Table 1 applies at any quantity, so the vehicle needs POISON GAS placards on each side and each end, and under 383.5 its driver needs a CDL with the H endorsement even though the vehicle is small.

What inspectors check

You can test your knowledge of the tables with the hazmat practice test, and find placard and function-specific training in the hazmat training directory. At the roadside, officers look for:

• Placards on all four sides, matching the shipping paper’s classes and the tables (172.504(a)).
• No placards for hazards not on board, and no leftover placards after delivery unless the bulk packaging still holds residue (172.502(a), 172.514(b)).
• Correct size, condition and position, including the 3-inch clearance from advertising (172.516, 172.519).
• ID numbers only where allowed and correct for the material (172.334).
• DANGEROUS used only for mixed Table 2 non-bulk loads, and replaced by the specific placard for 2,205 pounds of one category from one facility (172.504(b)).
• A driver with the H endorsement whenever placards are required (383.93(b)(4)).