Blog Article: Hazardous material safety and DOT

Hazardous material safety and DOT

By Ken Moyer, Brenntag Mid-South, Inc. / kmoyer@brenntag.com

Seems it is getting tougher on our roads with people moving to the great state of Florida daily. So, our job of making sure everyone gets home safely each night is getting that much tougher. Part of that safety is carrying hazardous chemicals and keeping the public safe in our daily travels. Thankfully, FDOT hasn’t paid attention to our industry but, things could change at any time so we need to be ready. Rob Sanger and I did an overview of DOT regulations at the Everything Under the Suns Expo and had multiple conversations during the show about tanks in trucks, labeling, luggage carriers and much more.  This made me think DOT regulation is the perfect topic going into pool season. Now, I am no expert on DOT and after reading through code prior to the show, it’s a full-time job. I am very grateful to David Rivers with RS Compliance Group for providing FSPA with the curriculum.

DOT regulations are complex with multiple chapters, so this is a really watered-down version for pool service. There are basically three ways to be classified depending on how much, container size, and trade use vs. delivery of chemicals.

Materials of Trade

Limited Quantity Exemption

Hazardous Materials Regulations like a trucking company.

Don’t forget to add sodium bromide, bag shock, and algaecides as EPA registered product you may have into your weight calculations. Sodium bicarbonate, DE, calcium and cyanuric acid are not included in DOT chemical weight.


Materials of Trade

Most pool service companies fall under this and it’s the simplest way to stay off DOT’s radar. No additional paperwork other than an SDS, and if you’re an FSPA member your INFOTRAC benefit has you covered. HAZMAT training is required.

440lb Maximum EPA registered products including Sodium Hypochlorite and acid products

No containers over 66lb = No 100lb drums of Trichlor, tablets or Cal Hypo

No liquid containers over 8 gallons.



12 Jerry Jugs / 30 gallons X 9.75=292.5lb

4 gallons acid X 9.66=38.64lb

50lb tabs = 50.00lb                                                             381.14lb Total

Greater than Materials of Trade designation

Maximum 999Lbs. total EPA registered products including sodium hypochlorite and acid products.  Must have shipping paperwork on truck. No containers over 66lb and No liquid containers over 8 gallons.



40 Jugs = (975lbs) and 2 gallons acid (19.25lb) = 994.52


38 jugs (926.25lb) and 4 gallons acid (39.04) =965.29 total

Hazardous Materials Regulations

Above 1,000 lbs. of EPA registered products and you are designated as a trucking company. Your company needs to have tracked training, paperwork, CDL, HAZMAT on license, DOT physical, HAZMAT registration, DOT # on truck, placards, pre-employment and random drug testing, along with much more. Without it, DOT fines can be in the $10,000 and up range.

Additional codes that qualify your company as a trucking company and other requirements:

Delivering bleach any size container.
Doesn’t matter if you’re carrying two jugs or 40 jugs for “delivery”. If you say your delivering jugs you’re the same as a trucking company. You need all the required information including additional 4” corrosive labeling on jugs, etc. Not to mention the child safety cap torque of 24 in. Lbs. required with an inspected torque wrench. Without it, DOT fines will be in the $10,000 and up range.

Pails, drums and totes must bear the required DOT markings, torque spec on container lids and Hazmat containers must be approved “UN” containers.
DOT Containers must be re-tested periodically
  a.  Drums and pails – 5 years
  b.  Totes- 2.5 years
  c.  Tests dates must be applied to
       the container

Bulk unloading from a truck tank to jug or tank. You are not allowed to discharge HAZMAT from a tote or tank while it remains on a vehicle without a special DOT exemption permit. Same goes for trailers without disconnecting them from the moving vehicle.

Drivers must have a CDL if operating a vehicle over 26K lbs. GVW regardless of HAZMAT.

If the vehicles exceed 26K lbs. gross vehicle weight, regardless of HAZMAT, the company must register with DOT.

If DOT registration is required, DOT requires a certain level of insurance be obtained.

Proper securement and segregation apply to all hazmat regardless of quantity. In most cases, shipping papers and training are required.


HAZMAT Training for staff and office

Everyone handling chemicals in your business needs to have training on them. If your business transports HAZMAT, it’s subject to DOT required training regardless of quantity or package size. The business activity determines training topics but there are three minimum topics for everyone. If you’re over Materials of Trade you’re required to have shipping papers. If shipping papers are required, the office people who prepare the document are required to have training as well.


As you can see, even the smallest business is subject to DOT training and shipping paper requirements. As companies get bigger, more administrative requirements come into play. Even the smallest company could be regulated as the biggest chemical company depending on the containers they carry. Stay safe out there; your family is counting on you.

Information provided by David Rivers at R S Compliance Group David@rscompliance.com.