If those totes are hauled on a flatbed, exposed to the view of enforcers, no tank endorsement, or placarding, is needed. If they are hauled inside a closed trailer/straight truck/van, the vehicle MUST be placarded, and the driver MUST have a tanker endorsement.
Landstar and I went round and round about this. I finally called FMCSA and asked for myself.
Exposed, no tanker endorsement and no placarding, since the totes themselves are marked.
Additional: (It appears Charles's post preempted my edit) Stop that!
After going back to the sources, Landstar and FMCSA, the GALLON requirement for a tanker endorsement is 1,000 gallons.
The placard rerquirement is inside an enclosed vehicle.
And, Charles, as was just explained to me, the reason for the requirement is surge of the product. So I would imagine if you were hauling more than 1,000 gallons of crstyal clear water, it would still be required. This entire regulation has zero to do with hazard class re: the tanker endorsement, and every thing to do with the behavior of the product inside the container.
Concealed, tanker endorsement and placarding required.