Interpretation Response #16-0026 ([Daniel Training Services] [Mr. Daniel Stoehr])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Daniel Training Services
Individual Name: Mr. Daniel Stoehr
Location State: IL Country: US
View the Interpretation Document
Response text:
July 21, 2016
Mr. Daniel Stoehr
Daniels Training Services
P.O. Box 1232
Freeport, IL 61032
Ref. No.: 16-0026
Dear Mr. Stoehr:
This responds to your February 17, 2016 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display of identification numbers on placards on a closed transport vehicle that contains materials with different identification numbers. Specifically you seek clarification on § 172.334(d) that states a placard bearing an identification number may not be used to satisfy the placarding requirements under Subpart F of Part 172 unless it is the correct identification number for all hazardous materials of the same class in the transport vehicle or freight container on which it is displayed.
You also enclosed two illustrations that show a transport vehicle displaying two placards each displaying different identification numbers. In the first illustration the transport vehicle displays two Class 8 Corrosive placards with different identification numbers. The second illustration shows a transport vehicle displaying two Class 3 Flammable liquid placards with two different identification numbers. Your questions are paraphrased and answered below:
Q1. As provided in § 172.334(d) can the identification number be displayed on a placard only if the identification number represents all of the hazardous material in the transport vehicle or freight container?
A1. If an identification number is displayed on a placard that identification number must represent all of the hazardous material of the same class on the transport vehicle or freight container. An identification number may be displayed on a placard even if a transport vehicle or freight container contains multiple hazardous materials. However, the transport vehicle or freight container must display additional placards as required, communicating the hazards of the other material in the transport vehicle or freight container.
Q2. It is your understanding that the intent of § 172.334(d) is to prohibit the display of an identification number on a placard when the hazardous material corresponding to the identification number does not meet the definition of the hazard class on the placard.
A2. Your understanding is not entirely correct. It is correct that any placard used for display of the identification number must correspond to the hazard class of the material. However, this requirement is outlined in § 172.334(b).
Q3. Is the display of the identification numbers on the placards in the two illustrations compliant with § 172.334(d)?
A3. The display of the identification numbers on separate placards complies with § 172.334(d) if the identification numbers displayed on the freight container or transport vehicle represent all of the hazardous materials in the transport vehicle or freight container.
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
172.334(d), 172.334(b)