Transporting Hazmat, Motor Vehicles and Machinery
Does your company transport machinery or motor vehicles? If so, you must register the specific Hazardous Materials carried on your MCS-150 USDOT Registration.
Okay, take a deep breath and don’t panic, these requirements don’t kick in the Hazardous Materials Regulations or require special endorsement on the Commercial Drivers License. Just don’t relax too much because you will most likely need to complete and MCS-150 Update.
In some of the recent DOT Compliance Audits we have been a part of, this has been one of the biggest issues for every new company who came to us seeking assistance. The investigating officers all made issue of compliance with the MCS-150 for failing to declare the Hazardous Materials.
This requirement was introduced in March 2017 and and became mandatory on January 2018. However, over the last couple years these requirements were mostly over looked and now the FMCSA Compliance Investigators are taking a hard line and penalizing companies for getting this wrong and failing to have the correct insurance levels.
Transportation of Machinery and Vehicles with an internal combustion engine fall under these three UN Numbers:
UN3528, Engine, internal combustion, flammable liquid powered or Engine, fuel cell, flammable liquid powered or Machinery, internal combustion, flammable liquid powered or Machinery, fuel cell, flammable liquid powered, 3
UN3529, Engine, internal combustion, flammable gas powered or Engine, fuel cell, flammable gas powered or Machinery, internal combustion, flammable gas powered or Machinery, fuel cell, flammable gas powered, 2.1
UN3530, Engine, internal combustion or Machinery, internal combustion, 9
When Updating Your MCS 150:
Section 24: Cargo Classifications
Check the appropriate fields, as follows:
Machinery, Large Objects
Section 25: Hazardous Materials Carried or Shipped
You must select both Class 3 and Class 9 Carried in Non-Bulk.
Additionally, if your company transports these machines and vehicles in interstate commerce you will be required to meet the requirements of 49 CFR 387.7 and must have a proof of the required insurance through a signed copy of the MCS-90 for $1,000,000 on file at the motors carriers office.
Frequently Asked Questions:
1. Do CDL Drivers transporting either machinery or motor vehicles need a “H” Hazardous Materials Endorsement?
Answer: No, a Hazardous Material Endorsement is only needed when a drivers carries an amount of hazardous material which requires Placards.
2. When transporting machinery or vehicle’s am I required to display Placards for Class 3 or Class 9?
Answer: No, the placarding requirements for Non-Bulk Table 2 commodities are only applicable when the Hazardous Material carried is 1,001 pounds or more. Additionally, Part 173.220 provides an exception from all hazardous materials requirements for internal combustion engines, vehicles, machinery containing internal combustion engines, battery‐powered equipment or machinery, fuel cell‐powered equipment or machinery.
3. Am I required to have a Hazardous Materials Shipping Paper?
Answer: No, Part 173.220 provides an exception from all hazardous materials requirements for internal combustion engines, vehicles, machinery containing internal combustion engines, battery‐powered equipment or machinery, fuel cell‐powered equipment or machinery.