Interpretation Response #05-0069
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Apr 26, 2005
Mr. Dave Madsen Reference No. 05-0069
Hazardous Materials Analyst-
Autoliv ASP, Inc.
3350 Airport road
Ogden, Utah 84405
Dear Mr. Madsen:
This responds to your March 25, 2005 letter regarding the marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), as they apply to a transport vehicle or freight container carrying Class 9 material.
Autoliv uses a CLASS 9 placard with the identification number ‘UN 3268” inscribed across the center. The marking requirement in § 172.336(b) specifies that an identification number displayed on a white square-on-point display configuration is not considered a placard. There is some confusion as to whether this provision applies to a Class 9 placard display.
When an identification number is not required or prohibited on a transport vehicle or a freight container under the HMR, § 172.336(b) prescribes requirements and options for display of an identification number. Provisions prohibiting display of an identification number are specified in § 172.334.
For a Class 9 material, a CLASS 9 placard is not required for domestic transportation under the HMR (see § 172.504(0(9)). However, a bulk packaging containing a Class 9 material must be marked with the appropriate identification number displayed on either a CLASS 9 placard, an orange panel, or a “white square-on-point”display configuration. A “white square-on-point” display configuration is not considered a placard under the HMR. Non-bulk packagings of a Class 9 material must be marked with the proper shipping name and the identification number of the material, and labeled (see § 172.301 and 172.400).
For your information, international shipments of a Class 9 material traveling through the United States may benefit from the domestic placarding exception in § 172.504(0(9). That is, a carrier may take advantage of applicable domestic exceptions specified in the IIMR when the hazardous material is transported within the United States even if transported under § 171.11, by aircraft, § 171.12, by vessel, or § 171.12a, to or from Canada.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 172.301||General marking requirements for non-bulk packagings|