USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #02-0043 ([R+L Carriers] [Dana Probasco])

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

Interpretation Response Details

Response Publish Date:

Company Name: R+L Carriers

Individual Name: Dana Probasco

Location State: OH Country: US

View the Interpretation Document

Response text:

February 22, 2002

Mr. Dana Probasco                 Reference No. 02-0043
Haz-Mat Specialist, Safety Dept.
R+L Carriers
P.O. Box 271
Wilmington, OH 45177-0271

Dear Mr. Probasco:

This responds to your February 6, 2002 letter concerning Placarding requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You ask how to placard a transport vehicle containing a Class 8 (corrosive), UN 1780, material in a bulk container weighing 1,500 pounds and a Class 3 (flammable liquid), UN 1993, material in a non-bulk package weighing 500 lbs.  Specifically, you asked if the weights of the two materials are added together to determine placarding requirements.

The answer is no.  Section 172.504(c) provides a placarding exception exclusively for non-bulk packages containing Table 2 materials, as defined in § 172.504(e), in a transport vehicle or freight container.  If the aggregate gross weight of the non-bulk packages and their contents is less than 454 kilograms (1,001 pounds), a placard is not required for these materials.  However, § 172.504(a) requires the transport vehicle or freight container to be placarded if it contains a bulk packaging of a Table 2 material.  Therefore, the correct placard for your packaging scenario is "CORROSIVE." Although § 172.502 permits the use of a "FLAMMABLE" placard in addition to the "CORROSIVE" placard, it is not required.

I hope this satisfies your request.

Sincerely,

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

172.504

Regulation Sections