Interpretation Response #07-0081 ([Pilot Chemical Company] [Mr. Matthew J. Leary])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Pilot Chemical Company
Individual Name: Mr. Matthew J. Leary
Location State: OH Country: US
View the Interpretation Document
Response text:
Jul 26, 2007
Mr. Matthew J. Leary Reference No. 07-0081
Corporate EHS Manager
Pilot Chemical Company
2744 E. Kemper Road
Cincinnati, OH 45241
Dear Mr. Leary:
This is in response to your letter dated April 12, 2007, requesting clarification as to who is responsible to ensure placards are affixed to an isotainer offered for transportation by highway to a rail yard under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the offeror or the carrier has the responsibility to affix placards to the isotainer in the scenario you describe.
As provided by § 172.514, each person who offers for transportation a bulk packaging which contains a hazardous material must affix the placards specified for the material in § 172.504 and 172.505. In addition to the placards required to be placed on a bulk package by the offeror, each person offering a motor carrier a hazardous material for transportation by highway must provide the motor carrier with the required placards for the material being offered prior to or at the same time the material is offered for transportation, unless the carrier"s motor vehicle is already placarded for the material. A motor carrier may not transport a hazardous material in a motor vehicle unless the placards required for the material are affixed to the motor vehicle (see § 172.506).
I hope this information is helpful.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.514, 172.504, 172.505