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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 #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

Section Subject
172.504 General placarding requirements