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?
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.
- 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.
- 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.
- Asbestos is regulated by U.S. DOT because it has a reportable quantity.
- 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.).
- 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.
- The U.S. DOT never requires placarding for domestic shipments of Class 9 material; however
- 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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