Bulk vs non-bulk

Bulk vs non-bulk: In hazmat rules, a bulk packaging holds hazardous material with no inner container, such as a cargo tank, with a capacity over 119 gallons for liquids. Smaller packages, such as drums, totes under that size and boxes, are non-bulk. The difference changes placards, markings and registration duties. Source

Where the line is

The federal definition: a bulk packaging holds hazardous materials with no intermediate form of containment, including a transport vehicle or freight container, and for liquids has a maximum capacity over 450 liters, 119 gallons. For solids it generally means a net mass over 400 kg, 882 lb, with a capacity over 450 liters. Source A tanker is bulk; a dry van full of 55-gallon drums is non-bulk, however many drums it carries.

Why it changes the paperwork

• Placards: a bulk packaging of a Table 2 material is placarded at any amount, while non-bulk Table 2 loads under 1,001 lb in total need none. Source
• Markings: bulk packagings show the UN number on placards or orange panels.
• Registration: bulk packagings of 3,500 gallons or more of liquids or gases trigger PHMSA registration. Source

In practice EXAMPLE

A carrier hauls 600 lb of a Class 8 corrosive in small jugs inside a van: non-bulk, under the 1,001 lb threshold, so no placards. The next week it hauls the same product in a 300-gallon tote: that tote is over 119 gallons, so it is bulk, and the van needs CORROSIVE placards for any amount. Check any mixed load with our placard checker and look up numbers with the UN number lookup. More in bulk hauling.

Why carriers get this wrong

The most common mistake is treating a large container as non-bulk because it looks like a package. A plastic tote that holds more than 119 gallons of a liquid is bulk, with the placard and marking rules that come with it, even inside a dry van. The second mistake is adding up drums and assuming the total makes them bulk; it doesn't, because each drum is its own packaging. Read the capacity marked on each container and the shipping papers before you load.

If you are not sure whether a load is bulk, ask the shipper before pickup and check the shipping papers, which describe the packaging.