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Hazmat · Placarding

A bulk packaging that had to be placarded has now been emptied of its hazardous cargo. When may the placards come off?

1.Not until it has been cleaned of residue and purged of vapors enough to remove any potential hazard, or refilled so that nothing hazardous remainsCorrect answer
2.As soon as the cargo has been unloaded at the consignee, since at that point the packaging no longer contains any hazardous material to warn anyone about
3.Once the vehicle is back inside the carrier's own yard at the conclusion of the run, since the public is no longer exposed to the residue
4.Placards may never be removed from a bulk packaging once they have been affixed to it, whatever is later done to clean or purge it

Explanation

The placards stay on while residue or vapor is still in the packaging: they come off once it has been sufficiently cleaned of residue and purged of vapors to remove any potential hazard, or once it has been refilled with something requiring different placards or none, to the point that any residue left behind is no longer hazardous. Residue and vapor are the hazard a responder actually meets, which is why unloading the cargo changes nothing by itself. Two narrower conditions in the same provision also release a packaging, and neither is in play here: holding the residue of a Class 9 hazardous substance in less than the reportable quantity while conforming to the empty packaging provision, and being an empty intermediate bulk container transported under that same provision. The second and third wrong options both turn on an event that leaves the residue exactly as it was, unloading the cargo or arriving back at the yard, and the fourth overcorrects into a permanence the regulation does not impose.

Source: 49 CFR 172.514(b)

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