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Interpretation Response #02-0177 ([Brenntag Mid-South, Inc.] [Fred E. Nichols])

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

Interpretation Response Details

Response Publish Date:

Company Name: Brenntag Mid-South, Inc.

Individual Name: Fred E. Nichols

Location State: KY Country: US

View the Interpretation Document

Response text:

Jul 24, 2002

Mr. Fred E. Nichols                 Reference No. 02-0177
Safety Director
Brenntag Mid-South, Inc.
P.O. Box 20
Henderson, KY 42419-0020

Dear Mr. Nichols:

This responds to your June 11, 2002 letter requesting clarification of the placarding requirements for poison/toxic inhalation hazard materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask for clarification on placarding requirements under §§ 172.505(f)(8) and 172.505(a) when transporting a poison/toxic by inhalation hazard (PIH) material such as, "Chlorine, 2.3, UN 1017."

According to your letter, your company has been cited for violations of the new PIH placarding requirements under § 172.505(a). According to the citation, you are required to placard the transport vehicle or freight container with the new PIH placard with the UN identification number across the center and hazard Class 2 at the bottom, and, with an additional PIH placard with the words "Inhalation Hazard" across the center of the placard and hazard class at the bottom.  It is your -understanding that the POISON GAS placard as shown in § 172.540 with the UN identification number across the center and Class 2 at the bottom is the only placard required for transporting Chlorine.

Your understanding of PIH placarding requirements in §§ 172.504(f)(8) and 172.505(a) is correct.  The POISON GAS placard for Division 2.3 materials as displayed in § 172.540 is the correct placard to be displayed when transporting a poison gas such as Chlorine.  The text "Inhalation Hazard" shown on the placard is optional; therefore, the UN identification number may be placed across the center of the Class 2 POISON GAS placard to satisfy the UN identification number marking requirement.  An additional PIH placard with the words "Inhalation Hazard" across the center is not required.  If the UN identification number is placed on the placard, the words "Inhalation Hazard" must be marked on the package.

I hope this answers your inquiry.


Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.505 Placarding for subsidiary hazards