Reefers and Explosives

[layoutshooter]

As you may or may not know it is illegal to put any class 1 explosive on a truck with a "cargo box heater" unless the unit has been disconected and the fuel tank(s) drained. Since I have no good way to do this I have taken our "explosives flag" off of the truck. I might understand not running the unit with explosives on board. I could even go for an electrical interupt switch on the reefer that would prevent the unit from being started from inside the truck when loaded with explosives. I don't understand draining the tanks. IF I had a seperate tank that I could drain, where would I dump 60 gallons of diesel legally? What about the fuel filters? You can't just throw them away. I hate giving up a potential source of revenue but I can't afford to run out of compliance. I can only just begin to imagine the fine for running illegal on an explosives load. Layoutshooter

 

[moose]

Don't tell me ...
Your loosing sleep over trying to make sense of FMCSA regulations ...




Moose.
Cleveland.

 

[layoutshooter]

LOL, no, I am not loosing sleep. I just marvel in the stupidity of most everything that involes a government agency. Layoutshooter

 

[FIS53]

Would it be possible to install a line with an inline electric fuel pump to take fuel from the reffer tank and pump it into the main fuel tanks? Separate switch etc for the pump that you use only when necessary. But would this work?
Rob

 

[layoutshooter]

I suspose you could, providing you have room for the fuel in your main tanks. You would still have the problem of the fuel filters. Then you would have to have new filters and have to insure that you had no air in the reefer fuel system etc. A lot of hassel. Right now I my case it does not matter. My reefer is hooked up to the main truck tanks. If I drained them then the reefer would be compliant but I would not go any where. Layoutshooter

 

[Booker]

In the past, we have had to run the reefer to carry class 1 explosives. The product was a prototype and had to be kept at a certain temperature. Our truck was equipped with a master shutoff switch for the reefer and we never had any trouble hauling explosives.

 

[layoutshooter]

Just be careful. I am sure a class 1 that required heating or cooling came with it's own exemption. As to "normal" class 1 loads, I checked with my carrier and they said that I am totally correct, it is not legal unless the tank is drained. Below is the note from out safety person. That is why I took that "flag" off my truck. Remember, your carrier may dispatch you on a class 1 load. The shipper may choose to load you. It is still illegal and if D.O.T. checks your truck and you have an illegal class 1 load it is your neck, no one elese. Layoutshooter


I just finished with the DOT Hazard division (PHMSA) and it has been verified the tank must be drained and disconnected. This is written in Section 177.834 of the 49 CFR for hazard regulations and in the Federal Safety Regs, section 392.67. There are no exceptions

 

[pelicn]

We've hauled explosives with our reefer truck, we just had to disconnect the battery. We don't have a separate fuel tank for the reefer.

 

[spudhead911]

I have hauled class 1 explosives with my reefer truck with no problem, I haven't heard of a rule that says you can't do it, but I could be wrong. Sometimes the shipper might specify that they don't allow reefer trucks to haul class 1 explosives, but that is just the shippers in house rule.

 

[layoutshooter]

The shipper will ship it if you will take it. It is a D.O.T. reg. I too have hauled class 1 on my reefer truck. I made the mistake of assuming that the shipper knew what they were doing. Then I went to pick up a load at a place in VA. I had asked my dispatch several times if they would load a reefer and was assured that they would. So I ran a 300 mile deadhead to pick up the load. When I got there the man running the shipping department said he would not load me. I explained what happened and how we were told it was ok to load the truck. He pulled out a huge book, D.O.T. regulations, and showed me the section that clearly stated that the tanks had to be drained. He said that he would not break any laws to load me and that he was sorry. I have looked this up in several sources and checked with the safety department with my carrier. There are no exeptions to that rule. You can do what you want. I just brought this up in here so other might learn. It is your business. It is likely that you will never be checked by D.O.T. when carrying class 1 out of compliance. I am not willing to risk my business on the off chance that I do get stopped. I recogmend that you look up the regulations. Do not take the word of the carrier or the shipper. Reguardless of what they say it is your responsibilty to know the regulations. Layoutshooter

 

[layoutshooter]

I want to make one thing clear. I did NOT write the sentence below. It was part of an email from my carriers safety department. They talked with D.O.T. to confirm what I asked. I left off the name of the person who wrote this, I did not think it right to post names of people without permission. Layoutshooter





I just finished with the DOT Hazard division (PHMSA) and it has been verified the tank must be drained and disconnected. This is written in Section 177.834 of the 49 CFR for hazard regulations and in the Federal Safety Regs, section 392.67. There are no exceptions

 

[pelicn]

I just finished with the DOT Hazard division (PHMSA) and it has been verified the tank must be drained and disconnected. This is written in Section 177.834 of the 49 CFR for hazard regulations and in the Federal Safety Regs, section 392.67. There are no exceptions

Here is where my confusion comes in...if you DO NOT have a separate fuel tank for the reefer, how can you drain and disconnect a tank that isn't there?

I found this reference to what constitutes a "Cargo Heater"
http://docketsinfo.dot.gov/reports/rspa/2007-07/060265.pdf

 

[layoutshooter]

You can't haul class 1 explosives then. I have the same problem. My reefer draws fuel off the main truck tanks as well. D.O.T. made quite clear to my carrier that it is NOT legal for me to carry ANY class 1 load. As of now, according to D.O.T., there are NO exceptions to that rule. Below is the sentence from the Hazardous Materials Compliance Handbook:


If the vehicle assigned to haul Class 1 materials is equipped to any kind of cargo heater, IT MUST BE INOPERABLE FOR THE DURATION OF THAT SHIPMENT. Check to be sure the heater's fuel tank has been completely drained and the power source dis-connected.


The part I put into capital letters was in bold in the book. I don't know how to make it bold. I had always carried class 1 loads. I too was under the impression that it was up to the shipper or that certain types of class 1 loads were safe with a reefer and other were not. That is not the case. I have no idea how old this regulation is or when it was last looked at by D.O.T.. I am not willing to chance running these loads knowing this. I don't know a good solution. Layoutshooter

 

[spudhead911]

Thanks for the information, most of us in the business have been hauling these loads for years with our reefer trucks thinking it was ok to do so.

 

[layoutshooter]

You are welcome. I put this out to inform as many as I can. What people do with the information is thier business. I know what I am doing, I no longer haul them. Layoutshooter

 

[jaminjim]

You can't haul class 1 explosives then. I have the same problem. My reefer draws fuel off the main truck tanks as well. D.O.T. made quite clear to my carrier that it is NOT legal for me to carry ANY class 1 load. As of now, according to D.O.T., there are NO exceptions to that rule. Below is the sentence from the Hazardous Materials Compliance Handbook:


If the vehicle assigned to haul Class 1 materials is equipped to any kind of cargo heater,
Check to be sure the heater's fuel tank has been completely drained and the power source dis-connected.


The part I put into capital letters was in bold in the book. I don't know how to make it bold. I had always carried class 1 loads. I too was under the impression that it was up to the shipper or that certain types of class 1 loads were safe with a reefer and other were not. That is not the case. I have no idea how old this regulation is or when it was last looked at by D.O.T.. I am not willing to chance running these loads knowing this. I don't know a good solution. Layoutshooter

Thats how you do it.

 

[Scott101]

Just how hot can a "reefer" unit make the cargo area anyway? Those dry vans get pretty warm all on their own in the summer...

Is the rule to thwart accidents, or on-purposes?

I'm not going to try and make sense of the regulation, but it's generally easier to accidently fuel the reefer then to accidently reconnect the battery. Just sayin...

 

[layoutshooter]

From what I understand it is not the heat but an ignition source. Layoutshooter

 

[Scott101]

Ah, gotcha.

Maybe a shutoff valve at the unit's fuel intake would get you a waiver? They can't be worried about the fuel itself can they? The main tanks are just a few feet away.

 

[layoutshooter]

We are going to look into several options. I don't think it will be easy or quick. At least I found out BEFORE in got inspected while carrying freight I was not allowed to carry. Layoutshooter