8.2 Bulk Package Markings and Identification Number Displays
Key Takeaways
- Bulk packagings display the identification number from Column 4 of the Hazardous Materials Table in black 100 mm (3.9 inch) numerals.
- The number may appear on an orange panel, across the center of the placard, or on a white square-on-point display when no placard is required.
- Specification cargo tanks must show re-test date markings.
- Portable tanks show the owner or lessee name plus the shipping name on two opposing sides, in letters at least two inches tall over 1,000 gallons and one inch tall under 1,000 gallons.
- If a portable tank's identification numbers are not visible once it is on the vehicle, the numbers must be displayed on both sides and both ends of the motor vehicle.
8.2 Bulk Package Markings and Identification Number Displays
[!IMPORTANT] Why this is its own topic: When a cargo tank rolls over on I-81, responders do not have time to open a cab and read paperwork. The four-digit identification number painted on the outside of the tank is what tells them, from a distance, whether they are looking at gasoline or anhydrous ammonia. The Virginia CDL manual devotes a full subsection to how those numbers must be displayed, and the knowledge exam tests the specifics.
The Identification Number Requirement
You must display the identification number of the hazardous material on portable tanks, cargo tanks, and other bulk packaging such as dump trucks. Identification numbers come from Column 4 of the Hazardous Materials Table.
The rules require black 100 mm (3.9 inch) numbers displayed in one of three ways:
| Display method | What it looks like | When it is used |
|---|---|---|
| Orange panel | Rectangular orange panel with black border, four-digit number in 3.9-inch black digits, mounted next to the placard | The most common configuration on petroleum and chemical tankers |
| Across the placard | The four-digit number printed across the center of the hazard placard on a white background bar | Used where the placard itself carries the number |
| White square-on-point | A white diamond the same size as a placard, showing the number in black | Used when no placard is required for the material |
[!WARNING] A white square-on-point display is the same size as a placard but is not a placard. It carries an identification number only. Test questions like to describe "a white diamond with 1993 on it" and ask whether the vehicle is placarded — it is not.
Specification Cargo Tanks: Retest Date Markings
Specification cargo tanks must show re-test date markings. During a pre-trip inspection or a roadside inspection, the specification plate and the periodic retest markings are what prove the tank is still authorized for the product inside it. A tank whose retest is out of date is not a legal package, no matter how sound it looks.
Portable Tank Markings
Portable tanks carry additional markings that cargo tanks do not:
- The lessee or owner's name must appear on the tank.
- The shipping name of the contents must appear on two opposing sides.
- The letters of the shipping name must be at least two inches tall on portable tanks with capacities of more than 1,000 gallons, and at least one inch tall on portable tanks with capacities of less than 1,000 gallons.
Where the Identification Number Goes on a Portable Tank
| Portable tank or bulk package capacity | Identification number must appear |
|---|---|
| 1,000 gallons or more | On each side and each end |
| Less than 1,000 gallons | On two opposing sides |
The visibility rule that follows from this: the identification numbers must still be visible when the portable tank is sitting on the motor vehicle. If they are not visible, you must display the identification number on both sides and both ends of the motor vehicle itself. A driver who slides a tank into a van body and drives away without transferring the numbers to the vehicle has created an unmarked bulk shipment.
Intermediate Bulk Containers
Intermediate bulk containers (IBCs) are bulk packages, so they carry identification numbers and are subject to the bulk placarding rule. But IBCs are not required to have the owner's name or the shipping name that portable tanks must display. This is a favorite distinction on endorsement tests: an IBC is bulk for placarding purposes, but it does not carry the portable-tank name markings.
Putting It Together on a Virginia Delivery
Roadside Case Study: A driver picks up a 900-gallon portable tank of UN1830, Sulfuric acid, 8, PG II at a chemical terminal in Chesapeake, Virginia, and loads it inside an enclosed van trailer for delivery to a water treatment plant.
On the tank itself, the driver verifies: the owner's name, the shipping name Sulfuric acid in letters at least one inch tall (the tank is under 1,000 gallons) on two opposing sides, and the number 1830 on two opposing sides.
Then the driver notices the problem: once the tank is inside the van, none of those markings are visible from outside. Because the identification numbers on the portable tank are no longer visible, the driver must display UN1830 on both sides and both ends of the motor vehicle, along with the required CORROSIVE placards. Without that transfer, the load is illegal even though the tank itself is perfectly marked.
What size and color must the identification numbers be on a cargo tank, portable tank, or other bulk packaging?
A portable tank with a capacity of 1,200 gallons is loaded onto a flatbed. Where must its four-digit identification number appear, and how tall must the shipping name letters be?
A portable tank of hazardous material is loaded inside an enclosed van so that the tank's own identification numbers can no longer be seen from outside. What must the driver do?
Which marking requirement applies to portable tanks but NOT to intermediate bulk containers (IBCs)?