How To Transport Bulk Diesel Without A HAZMAT

The Department of Transportation requires drivers that haul large quantities of diesel to obtain a state-issued CDL with a HAZMAT endorsement. There are a few exceptions in the Code of Federal Regulations that could mean big gains in productivity for your operation.

Thunder Creek has developed the first fuel and service trailer that can be towed by anyone with a standard driver’s license. In this guide, we’ll cover the applicable DOT Regulations and how the Multi-Tank Trailer legally eliminates the HAZMAT requirement when proper guidelines are met.

Straight From The Source

The Code of Federal Regulations (CFR) is the reference for rules published by the executive department and agencies of the Federal government. The topic of transporting diesel fuel is documented in Title 49. In this document, a HAZMAT endorsement to a state-issued Commercial Driver’s License (CDL) is required for transporting any hazardous material. The term “hazardous” is defined:

“Any material that has been designated as hazardous under 49 U.S.C. 5103 and is required to be placarded under subpart F of 49 CFR part 172…” 49 CFR 383.5

Diesel fuel falls under this definition. It is classified as a Class 3 combustible liquid. As such, it requires placarding. There is an exception from the placarding requirement for non-bulk packages of combustible liquids.

“Each person who offers for transportation or transports any hazardous material subject to this subchapter shall comply with the applicable placarding requirements of this subpart. This subpart does not apply to… Combustible liquids in non-bulk packagings.” 49 CFR 172.500

“Limited quantities of... combustible liquids are excepted from labeling requirements… The requirements in this subchapter do not apply to a material classed as a combustible liquid in a non-bulk packaging...” 49 CFR 173.150

Non-bulk packaging is defined as “any packaging which has a maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid.” 49 CFR 171.8 Thunder Creek’s Multi-Tank Trailers are configured with multiple 115 gallon tanks. Each tank is joined by a manifold to a common pump. This allows for complete isolation during transport.

A Note About CDLs and Vehicle Weight

In many cases, a CDL is not required to tow a Multi-Tank Trailer. However, there are some circumstances where larger trucks and fuel trailers will require the driver to have a CDL because of their weight. A truck and fuel trailer are considered a combination vehicle. A CDL is required for combination vehicles if both these circumstances apply. 49 CFR 383.91

1. The Gross Combination Vehicle Weight (GCWR) exceeds 26,000 lbs., and
2. The Gross Vehicle Weight Rating (GVWR) of the trailer exceeds 10,000 lbs.

A common misconception is that a CDL is required if only one condition is met. The CFR, however, only requires the CDL when both conditions apply. The GCWR is calculated as the GVWR of the truck plus the GVWR of the trailer. 49 CFR 385 This chart details the GVWR for many common trucks. The GVWR of Multi-Tank Trailers runs between 10,000 - 14,000 lbs.

Ford F-250 SRW 4x4 9,900 - 10,000 lbs.
Ford F-350 SRW 4x4 10,000 - 11,500 lbs.
Ford F-350 DRW 4x4 13,000 - 14,000 lbs.
Ram 2500 SRW 4x4 9,000 - 10,000 lbs.
Ram 3500 SRW 4x4 10,700 - 12,300 lbs.
Ram 3500 DRW 4x4 13,330 - 14,000 lbs.
GM 2500HD SRW 9,500 - 10,000 lbs.
GM 3500HD SRW 10,700 - 11,600 lbs.
GM 3500HD DRW 13,025 - 13,500 lbs.

Take Back Your Uptime

Most operations rely on small tanks in pickup beds or deliveries from a bulk supplier. Both are unnecessarily inefficient. You either have an employee who spends the majority of their day running between jobs or you have machinery sitting idle waiting for the fuel truck to arrive.

Ryan McKinney, owner of McKinney Excavating, understands this challenge. He runs three to four crews at any given time. All together, they can burn as much as 600 gallons of diesel a day. “It gets pretty challenging to keep a 110 gallon tank full all the time. You call to get bulk fuel and they’ll be there between one and three, similar to the cable guy,” says he says. “You have to figure out how you’re going to get enough fuel there to keep moving.”

Zero Cost of Ownership

Many operations find they are able to purchase fuel at a greater discount and the savings is enough to offset the monthly trailer payment.

Visit to calculate your cost to own a Multi-Tank Trailer.

Do You Need A CDL or HAZMAT?

Do You Need A CDL or HAZMAT?

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