Surely, taking a 55 gallon drum across a street does not trigger full compliance with the 49 CFR Department of Transportation (DOT), Hazardous Material Regulations? Yes, and I will not call you Shirley anymore. 

That seems to be the interpretation from the DOT Hazardous Materials Hotline (800-467-4922).  Backing this up is Subchapter I, Part 171, Section 171.1, Paragraph (d), in Sub-Paragraph (4). Or more simply in 171.1(d)(4). So, as my 2 year old granddaughter, Jolene likes to say,

 “Of course”.

“Rail and motor vehicle movements of a hazardous material exclusively within a contiguous facility boundary where public access is restricted, except to the extent that the movement is on or crosses a public road or is on track that is part of the general railroad system of transportation, unless access to the public road is restricted by signals, lights, gates, or similar controls.”

This would include any hazardous material container with residue, crossing a public road. They may not require hazardous materials shipping papers, or placards on the trucks for non-bulk 172.505 table to non-bulk containers, i.e. drum in 173.29(c). There is no exception for bulk containers over 119 gallons each or 882 pounds, fully regulated period. This would include forklifts. I am no expert on the DOT Federal Motor Carrier Safety Regulations. Could this trigger the requirements for commercial drivers license (CDL) with the hazardous materials endorsement for bulk containers like ICB or the totes?

Lock this down. If discovered or there is an accident, DOT might feel you willfully violated the requirements. That’s no joke.

Robert J Keegan

Publisher and President

Hazardous Materials Publishing Company

Transportation Skills Programs Inc.