HazMat Transportation

Transporting Class 9 Hazmat: HMEs and Registration

There seems to be much confusion regarding transporting class 9 hazardous materials (hazmat). Let’s take a look at two issues, one concerning the need for a hazmat endorsement and the other concerning registration.

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In the classification system of the U.S. Department of Transportation’s (DOT) hazmat, class 9 hazmat includes those that don’t come under any of the other hazmat classes (e.g., explosives, flammables). But, they are still hazardous materials, and there is a placard for them. But, does the placard have to be used?

What Is a Class 9 Hazmat?

Class 9 hazardous materials are miscellaneous hazardous materials. That is, they are materials that present a hazard during transportation, but they do not meet the definition of any other hazard class.

Class 9 hazmat includes:

  • Materials transported by air that could cause extreme annoyance to a flight crew member to the extent that it prevents the crew from performing its duties;
  • Hazardous wastes;
  • Hazardous substances;
  • Marine pollutants; and
  • Materials that meet the definition in the hazardous materials regulations (HMRs) for an elevated temperature material.

Is a Placard Ever Required for Class 9 Hazmat?

Not in the United States. A class 9 placard is not required for domestic transportation. This includes the portion of international transportation, which occurs within the United States. However, a bulk packaging containing a class 9 hazmat must be marked with the appropriate identification (ID) number displayed on either a class 9 placard, an orange panel, or a white square on point (i.e., diamond), which is not considered a placard.

Nonbulk packagings of class 9 materials must be marked with the proper shipping name and the ID number of the material and be labeled.

Do You Need an HME to Transport Class 9 Hazmat?

According to Pipeline and Hazardous Materials Safety Administration (PHMSA) officials, the requirement to have a hazardous materials endorsement (HME) on your license is triggered by placarding. PHMSA requires yearly registration for anyone who offers or transports in commerce a hazardous material that requires placarding. In addition, Federal Motor Carrier Safety Administration (FMSCA) regulations require that anyone transporting a hazardous material that requires placarding have an HME on his or her commercial driver’s license (CDL).

So, a driver of a commercial motor vehicle transporting a class 9 hazmat that is excepted from placarding for domestic transportation is not required to obtain an HME for his or her CDL.

What if You Use a Class 9 Placard?

The class 9 placard found at 49 CFR 172.560 (white diamond with 7 black vertical stripes on the top half and an underlined 9 centered in the bottom half) is primarily for use in international transportation. You are allowed to use it in the United States to display the ID number on a bulk packaging. However, if you use a class 9 placard for this reason (i.e., marking the appropriate ID number), the shipment is not subject to additional requirements applicable to shipments that require placards.

Do You Need to Be Registered to Haul Class 9 Hazmat?

Shipments that don’t require placarding don’t require that the person who offers for transportation, or transports, hazardous material be registered under PHMSA regulations at 49 CFR 107.601. So, you can accept a load that contains a class 9 hazmat without being registered with PHMSA.

But, Don’t Forget Training

Even though a driver transporting a class 9 hazmat is not required to obtain an HME for his or her CDL, that driver is still carrying a hazmat under PHMSA regulations and must receive hazmat training. The training must include general awareness, function-specific, safety, and security awareness training under PHMSA regulations as well as driver training in the applicable FMCSA regulations and the procedures necessary for the safe operation of the motor vehicle.


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