Interpretation Response #07-0074 ([Veolia Environmental Services] [Ms. Jennifer Eberle])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Veolia Environmental Services
Individual Name: Ms. Jennifer Eberle
Location State: NJ Country: US
View the Interpretation Document
Response text:
May 15, 2007
Ms. Jennifer Eberle Reference No. 07-0074
Manager, Transportation Compliance
Veolia Environmental Services
One Eden Lane
Flanders, NJ 07836
Dear Ms. Eberle:
This responds to your April 10, 2007 letter requesting clarification on the use of the
DANGEROUS placard under § 172.504(b) of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for confirmation that the DANGEROUS placard is not required in your situation.
According to your letter, you have a truckload shipment of 3,300 pounds total aggregate gross weight of three Table 2 materials in non-bulk packages as follows: Class 8 and Class 3 materials (500 pounds each) and Division 5.1 material (2,300 pounds) loaded at one loading facility.
Section 172.504(b) authorizes the use of the DANGEROUS placard instead of the separate placards specified for the three hazardous materials in Table 2 for shipments of two or more categories of Table 2 materials in non-bulk packages that require different placards. Thus, the DANGEROUS placard is authorized for your mixed truckload shipment. However, when 1,000 kg (2,205 pounds) aggregate gross weight of more than one category of material is loaded at one loading facility, the placard specified in Table 2 for that category must be applied. The DANGEROUS placard is already authorized for use on the mixed truckload shipment, but, since the aggregate gross weight of the Division 5.1 material exceeds the 2,205 pound threshold, the OXIDIZER placard is now also required to cover the 2,300 pounds of Division 5.1 material that was loaded at one loading facility. Therefore, both the DANGEROUS and OXIDIZER placards should he used for this mixed truckload shipment to indicate the presence of both the Class 8 and Class 3 materials, as well as the Division 5.1 materials.
I hope this answers your inquiry.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.504(b)
Regulation Sections
| Section | Subject |
|---|---|
| 172.504 | General placarding requirements |