When your vehicle is stopped and inspected by the DOT (Department of Transportation), the proper tank markings are going to have to be in place if you’re carrying hazardous materials. Does your tank have the correct marking for the manual remote shutoff device? For some reason, for the last several years, one of the most frequently violated hazmat regulations is that of the manual remote shutoff device requirement for proper signage/marking. Here are some statistics:
- 2016 to 2017 – When stopping trucks for inspections, improper marking of shut off devices was regularly found. On the list of violations found by the DOT, it ranked 17th.
- 2017 to 2018 – This disturbing trend continued and, in fact, on the DOT’s list of violations, ranked 14th.
Is your cargo tank marked correctly? If you have more than one tanker and are operating a fleet, every tank needs to be appropriately marked to satisfy DOT regulations.
First things first – what is a cargo tank according to the DOT? These tanks are, more or less, bulk packaging that:
- Is not fabricated under a specification for tank cars, portable tanks, multiunit tank car tanks, intermediate bulk containers, or cylinders.
- Forms a part of or is permanently attached to a motor vehicle. Or, by reason of its attachment to a motor vehicle, its construction, or its size, is not permanently attached to a motor vehicle and can be unloaded or loaded without being separated.
- Is a tank whose primary intention is for the carriage of gases or liquids and includes closures, fittings, reinforcements, and appurtenances.
Proper Markings for the Emergency Shutoff
Since October 2005, in response to a National Transportation Safety Board recommendation, the topic of “Emergency Shutoff” markings was addressed. For the closure of the eternal valve, all manually activated on-truck remote shut off devices would be required to be marked “Emergency Shutoff”. The color of the lettering must be in direct contrast with its background and the height of the lettering must be at least 0.75 inches.
There does exist, however, a point of confusion which is as follows: “Immediately adjacent to” the means of closure is where the location of emergency shutoff markings must be found. DOT roadside inspectors and PHMSA officials have disagreed when some tanks were cited for violation by the inspector. Addressing this concern, here are some guidelines from the PHMSA (Pipeline and Hazardous Materials Safety Administration).
In order to be “immediately adjacent to” the emergency closure device, it is not specified exactly what the distance of the emergency shutoff marking must be. Here is one example of a company that had a problem with their emergency marking:
A company was cited by a DOT roadside inspector by for not meeting the requirement of the emergency market being close enough to the closure device. When, however, the company sent a picture and description of the area of concern to the PHMSA – contesting the citation – the PHMSA official agreed with the company. The signage was indeed close enough to the emergency closure device.
What you can take away from this is that if your company is cited for improper emergency signage, you can contest/protest the citation. Compile all the information you can about the person issuing the citation, take pictures of your signage, write down detailed descriptions, and be prepared – at a hearing if necessary – to present all of your information.
Do You Carry Emergency Signage on Your Vehicle?
If your vehicle or trailer contains emergency signage, Mickey Genuine Parts has just what you need. Our Flip Place Cards Front/Side Safety Signs are available for purchase to make sure that you are in compliance with all rules and regulations.
Contact us to find out what Mickey can do for you, today.