Interpretation Response #02-0089
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
APR 15, 2002
Ms. Barbara Konrad Reference No.: 02-0089
Manager, Transportation Safety
Honeywell International, Inc.
P. O. Box 1057
Morristown, NJ 07962-1057
Dear Ms. Konrad:
This is in response to your letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that during an audit by the Federal Railroad Administration (FRA), disagreement arose over the correct placarding for a tank car containing hydrogen fluoride, anhydrous. It is your understanding that Division 6.1 (other than Inhalation Hazard Zone A or B) materials must be placarded POISON (see §§ 172.504(e) and 171.14(b)) and that § 172.519(b)(4) allows the use of the POISON placard in lieu of the POISON INHALATION HAZARD placard.
The current HMR requirements for placarding shipments of hydrogen fluoride, anhydrous, are confusing and will be addressed in an upcoming rulemaking. A tank car containing hydrogen fluoride, anhydrous, must display CORROSIVE and POISON INHALATION HAZARD placards.
Your understanding of the placarding table in § 172.504 and the transitional provisions in § 171.14 is correct: Poisonous by inhalation (PIR) liquids are typically assigned to either Inhalation Hazard. Zone A or B. Hydrogen fluoride, anhydrous, a corrosive liquid which also meets the definition of a PIH material in § 171.8, is an exception in that it is assigned to Inhalation Hazard Zone C. The subsidiary placarding requirements in § 172.505(a) require that the transport vehicle must be placarded with the POISON INHALATION HAZARD placard in addition to any other required placards. It applies to PIH materials in all hazard zones. Section 172.519(b)( 4) does not apply. This latter provision addresses the display of the hazard class or division number in the lower comer of a placard and the transition period that permits continued use of subsidiary placards without the hazard class or division number in domestic transportation by rail or highway.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 172.505||Placarding for subsidiary hazards|