By: Terry Poland
DG Instructor, Transportation Development Group
© 2019Recently, a good customer of ours sent a tech-support question regarding a Class-7, Radioactive Material shipment. When I explained to this freight forwarder that Yellow-III Radioactive Materials are considered to be “high-consequence” hazardous materials, and they require hazmat registration and an in-depth security plan, he replied, “I am leaning towards declining [the shipment].” I told him, “that’s my sentiment exactly.” As it turns out, I learned an old lesson again: there are exceptions to almost every rule. In this case, the hazmat registration requirement still applies to this radioactive shipment; however, the security planning aspect has a few loopholes (one of which was his radioactive package, since it did not meet the “highway route control quantity” definition in 49 CFR 173.403). The fact is that most hazmat shippers and carriers are somewhat familiar with the placarding requirements found in 49 CFR, 172.500 (subpart F). Essentially, the nine hazard classes and various divisions are divided up into two tables – appropriately named Table 1 & Table 2. The first contains materials considered to be of a “high-consequence” danger and the second everything else. Most important, Table-1 materials, such as High Explosives, Dangerous When Wet and Toxic by Inhalation, all mandate placarding trucks and containers carrying ANY amount. Table-2 only requires placards when an aggregate of more than 1,000 pounds is loaded at one time. But meeting these placarding requirements only scratches the surface. The real kicker with shipping such high-danger materials is “The Table-1 Trigger.” When a shipper or carrier, including freight forwarders and other intermediaries, handles materials from Table-1, it automatically triggers the requirement for DOT Hazmat Registration (per 49 CFR 107.601); and, in MOST cases, it also requires initiation of an in-depth security plan (per 49 CFR 172.800 – which includes most Table-1 materials and some other materials shipped in “large bulk quantities”). Along with the registration requirement are hefty fees – yearly; and with the additional security plan more costly hazmat employee training requirements. For small businesses and non-profits, this yearly fee is $250, for all others it is a whopping $2,575. In summary, the registration and fee requirement applies to anyone who transports or offers to transport ANY placarded item. The requirement to implement an in-depth security plan and train staff in the same applies to anyone who ships or transports any of the materials set forth in 49 CFR 172.800. So shippers and carriers need to think twice when determining their operating procedures for these hazardous materials. Our recommendation is to stay away from Table-1 and other high-consequence materials or get ready to pay the extra price tag. For more detailed information, see our Knowledge Base Article.