Reefers and Explosives

[bernieh48]

We have been told that the draining of the tanks is only for tractors pulling reefer trailers as their reefers run off their own fuel source under the trailer. With straight trucks it's not that way. The key wording in that reg. is that it is made inoperable. We have been told by Crane,In that as long as the battery is disconnected that constitutes it being ok to haul in a straight truck! Crane , In is one of the biggest sticklers on regs and rules so I trust their judgement everyday. And we have been stopped and inspected several times by DOT and looked over with a fine tooth comb including checking the battery connection when hauling class 1 and never been sited for it.

 

[layoutshooter]

Do you have a contact we can talk with? D.O.T. told our safety department that we could not do that. I would love to have our safety people talk with someone there. I really would like to have that source of revenue. Layoutshooter

 

[pelicn]

The link I posted above is from the DOT...and it says a reefer is ok on a straight truck without a separate fuel tank, as long as you disconnect the battery.
So now I'm really confused!!

 

[layoutshooter]

You can't be as confused as I am. May I copy that letter and send it to our safety department? I don't want to send it without your permission. I really hate dealing with the government. You can talk with 6 people from the same agency about the same problem and get 8 different answers. Layoutshooter

 

[pelicn]

I found the link on the net, so I assume it's ok to copy it.

 

[bernieh48]

Thanks pelicn I knew there was something on it as I don't think as big as Panther is they would risk it.

 

[layoutshooter]

Thanks, I will copy the link. I still have been turned away at more than one shipper. This is very confusing. I thought the same, a big shipper would know. That is why I had safety call the D.O.T. for clarification. I passed along what they told safety. Layoutshooter

 

[dabluzman1]

As for the battery issue, on our unit with the battery for the reefer inside the passenger
door steps, we have a cut-off switch. It is located on the outside of the steps. Flip it and the power is cut to the entire system. Even the control box wont light up.

Cavs 90 Det 80.....in Detroit.

 

[layoutshooter]

If I get a "go" from safety the battery cut off switch is my first choice. Tank draining is just plain stupid. Layoutshooter

 

[pelicn]

We've also been turned away because we have a reefer. Crane makes us completely disconnect the battery before they will load us.

 

[layoutshooter]

It is such a pain when that happens. Even if I get set up in such a way that D.O.T. is happy I think I still might avoid long dead heads on explosive loads. Layoutshooter

 

[cliffn]

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

Time Out! I really think everyone needs to take a look at the link provided by pelicn which really gets to the point. What IS a cargo heater??

A few years back when my wife and I were driving a big truck (18 wheeler) we hauled a load or two that used a cargo heater which was a portable unit placed inside the trailer to provide heat so the load did not freeze. Perhaps many are not aware that there are units of this type out there.

Check out that link in pelicn's post. It shows a letter written by a Kenworh dealer trying to find out if the reefer unit is a cargo heater. The writer describes the truck in detail and it is the typical reefer you find in straight trucks. He asks if that would be considered a "cargo heater"

The answer then by John A Gale from the Office of Hazardous Materials Standards Of USDOT states: ....."it is the opinion of this office that your mechanical refrigeration unit does not constitute a "cargo heater" as that term is used in 177.834(1)(1) of the HMR."

Am I missing something with that? Certainly, it us understandable that you don't want something that could cause a fire with a load of explosives so you don't want one of those heaters in with the load but it appears that that rule is NOT talking about a reefer unit.

Check that link. When you bring it up the answer page comes up and then the question (backwards)..

 

[moose]

I remember Pulling a load of Chemicals going to up state Maine in the middle of winter .
temp was under 10* most of the way , and it was stated clear on the BOL that the drums are not to get frozen .
indeed the reefer show 42* all the way , and the Engine will kick in every now and then , just like on cooling mode .
when i got to Del. the receiving guy inspected every single drum to make sure it did not freeze enroute .
so i can only assume that those reefer trailers can heat too.
and the heated trailers have no fuel tanks , they work on propane.
dont know 'bout St. Trucks reefer - dont have one ,
I'm just saying...

this is a clear safety issue , might just be that those reg, have being wrighten in blood
will you take the chance ?



Moose.

 

[pelicn]

Moose, a cargo heater is different than a reefer unit. We used cargo heaters for beer loads when we drove T/T.
A reefer unit can heat or cool depending on what temperature you want.

 

[layoutshooter]

The problem we are running into is that some shippers, mainly military, consider a Temp control unit a heater if it can heat the cargo box. I went to DOT site and read and read. It seems that some officials consider reefers (tcu's) that heat the cargo box a heater. Go figure, it is a government agency, why should it surpise me? It don't. Layoutshooter

 

[ConfusedMuse]

It's all in how anyone interprets the written word (s). We all hope that we get the Official that interprets the specific law the way we want it to be.

 

[layoutshooter]

Yea, I just want to know what D.O.T. considers a cargo box heater. If I have one, fine, I don't care. I just want one answer that I can depend on. Of course it is a government agency. I might just be wasting my time. Layoutshooter

 

[transporter]

my company policy is you are never to smoke reefer while hauling explosives.

 

[layoutshooter]

Same with ours but it ok on "ART" loads!!! LOL Layoutshooter

 

[layoutshooter]

UPDATE!!! I heard from out Safety department and D.O.T. concures that we DO NOT have a cargo heater as described in the regs. We DO have to carry a copy of the "Docket" that Pelican posted earlier and that I have posted below. That is not to say that a shipper will never turn you away again but it SHOULD save you from problems with a D.O.T. inspection. Acording to what D.O.T. told Safety this only applies to straight trucks. ATTENTION FDCC
CONTRACTORS!!!! Check out the ExtraNet for further information. There is a post on there about this. Thanks again to Saftey for your timely help. Layoutshooter

http://docketsinfo.dot.gov/reports/rspa/2007-07/060265.pdf