Interpretation Response #99-0291 ([Motor Carrier Compliance Office] [Captain Ken Carr])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Motor Carrier Compliance Office
Individual Name: Captain Ken Carr
Location State: FL Country: US
View the Interpretation Document
Response text:
December 17, 1999
Captain Ken Carr Ref. No. 99-0291
Motor Carrier Compliance Office
Hazardous Materials Enforcement
1615 Thomasville Road
Tallahssee, FL 32303-5750
Dear Captain Carr:
This is in response to your letter dated October 11, 1999, regarding permissive placarding under § 173.502(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter you describe the shipment of combustible liquids under § 173.150(f)(2). Your questions have been paraphrased and answered as follows:
Q1. May COMBUSTIBLE placards be displayed on a vehicle transporting a combustible liquid in a non-bulk packaging that is not a hazardous substance, a hazardous waste, or a marine pollutant.
Al. The answer is yes. Section § 172.502(c) permits the display of placards for a hazardous material, even when not required, if the placards represent the hazard of the material being transported.
Q2. If a carrier chooses to display placards on a vehicle transporting combustible liquid"s under the exception in § 173.150(f) (2), is there a requirement to comply with other requirements of the HMR?
A2. The answer is no. Combustible liquids meeting the criteria specified in § 173.150(f)(2) are not subject to the HMR. The HMR include, but are not limited to, shipping paper, marking, labeling, and placarding requirements. A carrier who chooses to display appropriate placards even when not required, is not subject to other provisions of the HMR.
Q3. If shipping papers are provided for a hazardous material that is excepted from the HMR, does any violation exist if the shipping papers are not executed in conformance with the HMR?
A3. The answer is yes. If the shipper chooses to provide a hazardous materials shipping paper, the shipper must do so in accordance with all the requirements in Part 172, Subpart C.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.150
Regulation Sections
| Section | Subject |
|---|---|
| 173.150 | Exceptions for Class 3 (flammable and combustible liquids) |