DOT Shipping Asbestos

Question: We are shipping asbestos wastes in bladder bags. The U.S. DOT says our driver must have a commercial drivers license with a hazmat endorsement. Is that true?

Situation

The waste handler transports asbestos waste in bladder bags in a vehicle with GVW (gross vehicle weight) of 34,700 pounds. They have been told by DOT that their driver requires a special license. This was surprising to them since they had not previously known of any such requirements.

Recommendations

  1. Since you are hauling in bulk containers (that is, larger than 119 gallons in size) and with a truck exceeding 26,000 lb GVW, you not only are required to have a driver with special qualifications, but you must also have the ID number (2212) for asbestos displayed on the outside of the vehicle.
  2. If you change to a smaller truck (<= 26,000 lb GVW) and smaller containers (double-bagged in strong bags of less than 66 lb gross weight) then no special requirements would apply.

Analysis

The Law.

  1. Asbestos is regulated by U.S. DOT because it has a reportable quantity.
  2. It is regulated as a Class 9 environmentally hazardous material because it has no other DOT hazards (that is, it does not meet the definition of "corrosive" or "poison" or "flammable", etc.).
  3. The U.S. DOT requires that the driver of a hazardous material transport vehicle have a commercial drivers license with a hazardous materials endorsement if
    • the load is placarded, or
    • the vehicle exceeds 13 tons (26,000 lb) gross vehicle weight.
  4. The U.S. DOT never requires placarding for domestic shipments of Class 9 material; however
  5. they do require the posting of the ID number on any bulk shipment of a hazardous material. For asbestos this posting can be
    • the ID number (2212) in a Class 9 placard, or
    • the ID number in a plain white placard, or
    • the ID number in black letters on an orange rectangle.

The Issues: As noted in the Recommendations section, if you don't want to meet these requirements, change to a smaller truck and to nonbulk containers.

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