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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0209 ([Applied Specialties, Inc.] [Ms. Adrainne B. Scheurman])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Applied Specialties, Inc.

Individual Name: Ms. Adrainne B. Scheurman

Location State: OH Country: US

View the Interpretation Document

Response text:

October 5, 2001


Ms. Adrainne B. Scheurman              Reference  No.: 01-0209
Compliance Manager
Applied Specialties, Inc.
33555 Pin Oak Parkway
Avon Lake, OH 44012

Dear Ms. Scheurman:

This is in response to your letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you asked if a cargo tank that previously transported a Class 9 material in domestic commerce and was placarded “Class 9" must remain placarded when it is empty, but has not been cleaned.

The answer is no.  The requirements in § 172.514(b) that a bulk packaging must remain placarded when it is emptied apply only to required placarding.  As provided in § 172.504(f)(9), placards are not required on a bulk packaging containing a Class 9 material in domestic transportation.  However, a bulk packaging containing a Class 9 material must be marked on each side and each end with the appropriate identification number.

I trust this satisfies your inquiry.



John A. Gale
Transportation Regulation Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.504 General placarding requirements