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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 #05-0050 ([Arkema Inc.] [Ms. Christina M. Kurtz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arkema Inc.

Individual Name: Ms. Christina M. Kurtz

Location State: PA Country: US

View the Interpretation Document

Response text:

Mar 23, 2005

Ms. Christina M. Kurtz                 Reference No. 05-0050
Supervisor - Regulations and Packaging
Arkema Inc.
2000 Market St.
Philadelphia, PA 19103

Dear Ms. Kurtz:

This is in response to your February 23, 2005 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code. Specifically you ask who is responsible for removing placards from a. freight container after transportation ends.

Under § 172.602 of the HMR, no person may affix or display on a freight container any placard described in Part 172, Subpart F unless the placard represents a hazard of the hazardous material being offered or transported. The person who will re-offer the freight container for transportation will be responsible for ensuring the appropriate placards are applied to the freight container including removal of any existing placards that are not applicable to the current load.

Under the IMDG Code, paragraph states: “all placards, orange panels, marks and signs shall be removed from cargo transport units or masked as soon as both the dangerous goods or their residues which lead to the application of those placards, orange panels, marks or signs are discharged.” The IMDG Code does not specify who must perform this task; however, a carrier will be in violation of the IMDG Code and the HMR if it transports an empty freight container with placards still applied.

You should also be aware that the Department of Labor’s Occupational Safety and Health Administration regulations require an employer to retain all hazardous materials markings, labels and placards on incoming packages, freight containers, rail freight cars, motor vehicles and transport vehicles containing hazardous materials, until the material is sufficiently removed from the package, container or vehicle to prevent any potential hazard (29 CFR 1910.1201)

I hope this satisfies your request.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions