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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 #04-0015 ([Jevic Transportation] [Mr. Samuel V. Yardurnian])

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

Interpretation Response Details

Response Publish Date:

Company Name: Jevic Transportation

Individual Name: Mr. Samuel V. Yardurnian

Location State: NJ Country: US

View the Interpretation Document

Response text:

Feb 2, 2004

Mr. Samuel V. Yardurnian                Reference No. 04-0015
Hazardous Materials Specialist
Jevic Transportation
700 Creek Road

Delanco, NJ 08075

Dear Mr. Yardurinian:

This is in response to your letter dated January 9, 2004 requesting guidance pertaining to large quantities of a single hazardous material transported in non-bulk packages, as established under
§ 172.301(a)(3) of the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180).  Specifically, you state that a shipper loads 11,000 pounds of flammable liquid, that is marked with the same identification number and proper shipping name, at one loading facility.  Further, you state that you are not required to mark the transport vehicle on each side and each end with the identification number because there is other freight present on the vehicle when the flammable liquid is loaded.  However, you ask if a driver is required to affix the identification number corresponding to 11,000 pounds of flammable liquid if he delivers all of the non-hazardous freight, leaving only the 11,000 pounds of flammable liquid on the transport vehicle.

The answer is no.  The marking requirement found in § 172.301(a)(3) is applicable to the material within the transport vehicle at the time that a large quantity of a single hazardous material in non-bulk packages is loaded.  In your example, the transport vehicle contains other freight when the flammable liquid is loaded; therefore, the transport vehicle is not required to be marked with the identification number of the flammable liquid.  In our opinion, so long as the shipping paper indicates that the vehicle once held other freight and the driver is familiar with
§ 172.301(a)(3), these provisions would apply for the duration of the deliveries.

Additionally, the identification number may be permissively displayed on the transport vehicle on each side and each end.  This practice would identify the material and alleviate the potential for a frustrated shipment.

I hope this satisfies your request.



Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings