Recently, a driver carrying a load of empty drums containing small amounts of hazardous materials residue was stopped by the police. Following a brief investigation, it was discovered that the driver's Commercial Drivers License (CDL) did not carry a hazardous materials endorsement.

The police said the rule requiring a HazMat endorsements on a CDL applies to anyone transporting even small amounts of hazardous materials in a commercial vehicle. The company for whom the driver worked said the rule does not apply since the amount of material in question was so minor.

Who was right?

In this case, the company was correct. The applicable rule comes from the Federal Motor Carrier Safety Regulations (49 CFR Part 383). Section 383.93(b)(4) states that a hazardous materials endorsement is required "to operate commercial motor vehicles which are... required to be placarded for hazardous materials."

For drum reconditioners, who do not require placarding under 49 CFR 173.29(c)(1), such an endorsement is, therefore, not required.

From Reusable Industrial Newsletter.