Hauling pesticides: DOT, placards and decals

What counts as a material of trade

DOT defines a material of trade as a hazardous material, other than hazardous waste, carried by a private motor carrier in direct support of a principal business that is not transportation. A pest company hauling its own products to its own jobs fits that description.

The exception covers Class 3, 8 and 9 materials and Divisions 4.1, 5.1, 5.2 and 6.1 within set package sizes: up to 1 pound or 1 pint for Packing Group I, and up to 66 pounds or 8 gallons for Packing Group II or III. All materials of trade on one vehicle may not exceed 440 pounds gross. Hazardous waste, self-reactive materials and materials poisonous by inhalation are excluded.

Check each product’s safety data sheet for its hazard class, packing group and any inhalation hazard before you count it as a material of trade.

The rules you still have to follow

Packages must be leak tight for liquids, sift proof for solids, securely closed, secured against shifting and protected against damage. Use the manufacturer’s original packaging or one of equal or greater strength.

Each non-bulk package must be marked with a common name or proper shipping name, plus "RQ" if it holds a reportable quantity of a hazardous substance. The driver must be told that hazardous materials are aboard and what this section requires.

When placards and a CDL come in

Carry more than the Materials of Trade limits and the exception no longer applies; the rest of the hazardous materials regulations do. For materials in placarding Table 2, placards are not required below 1,001 pounds aggregate gross weight, except for bulk packagings and materials covered by 49 CFR 172.505.

The CDL rule turns on placards. Federal CDL rules treat a vehicle of any size as a commercial motor vehicle if it carries hazardous materials that must be placarded. The driver then needs a CDL with a hazardous materials endorsement, which requires a knowledge test.

State decals, storage and spill rules

South Carolina requires every vehicle that transports pesticides to and from a job, or is used to apply them, to carry a Department of Pesticide Regulation identification symbol on both sides, kept clean and readable from 100 feet. Company cars that never haul pesticide do not need one.

Georgia’s Structural Pest Division tells companies that pesticides must be in a locked compartment, such as a truck toolbox, whenever they are out of the applicator’s view. Service containers must carry the product name and EPA registration number, food containers are never allowed, the label must be available to the person applying, and each truck needs a spill kit big enough for the largest potential spill.

This is general information, not legal advice. Confirm with PHMSA’s Hazardous Materials Information Center, your state pesticide agency or a transportation attorney.