Interpretation Response #98-0508 ([The Dow Chemical Company] [Mr. Hugh Taylor])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Dow Chemical Company
Individual Name: Mr. Hugh Taylor
Location State: MI Country: US
View the Interpretation Document
Response text:
JAN 6, 1998
Mr. Hugh Taylor
Regulatory Specialist
The Dow Chemical Company
2020 WH Dow Center, C-1306
Midland, MI 48674
Dear Mr. Taylor:
This is in response to your letter dated November 5, 1997, regarding residues of Class 9 hazardous substances under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether tank cars and cargo tanks that contain residues of Class 9 hazardous substances may be returned from the consignee without removing the ill number marking and/or the placards.
The answer is yes. The HMR do not require removal of the identification markings and/or placards when a package has a residue of a Class 9 hazardous substance. However, the shipping paper should be consistent with the transport vehicle's hazard communications by prefacing the shipping description with "RESIDUE Last Contained ***" as provided by § 172.203(e)(1). However, markings or placards may be removed when the Class 9 hazardous substance residue is below its reportable quantity. No shipping paper is necessary if placards and markings are removed.
I hope this information is helpful. If we can be of further assistance, please do not hesitate to contact us.
Sincerely,
Delmer F. Billings
Chief, Regulations Development
Office of Hazardous Materials Standards
Regulation Sections
| Section | Subject |
|---|---|
| 172.300 | Applicability |
| 172.512 | Freight containers and aircraft unit load devices |