Interpretation Response #05-0157 ([Laidlaw Corporation] [Mr. Tom Beckman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Laidlaw Corporation
Individual Name: Mr. Tom Beckman
Location State: AL Country: US
View the Interpretation Document
Response text:
Jul 20, 2005
Mr. Tom Beckman Reference No. 05-0157
Chemical Products Manager
Laidlaw Corporation
5326 Industrial Park Road
Metropolis, Illinois 62960
Dear Mr. Beckman:
This responds to your June 16, 2005 letter requesting clarification on placarding under
§ 172.500(b)(6) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask how to placard a mixed load of non-bulk packagings containing combustible liquids, corrosive liquids, and Packing Group 1111, Division 6.1 poisonous materials.
According to your letter you were cited for not having the COMBUSTIBLE placard on your vehicle. Your vehicle was placarded as follows:
CORROSIVE placard for 2,835 pounds of corrosive liquids (in non-bulk packagings) DANGEROUS placard for 5,000 pounds but less than 6,000 pounds of combustible liquids (in non-bulk packagings) and less than 1,000 pounds of Packing G III, Division 6.1 poisonous materials (in non-bulk packagings)
In accordance with § 172.5 00(b)(6), combustible liquids in non-bulk packagings are not required to be placarded. Section 172.504 authorizes the use of the 1)ANGEROUS placard for two or more Table 2 hazardous materials in lieu of the specific placard for each hazard class until 1,000 kg (2,205 pounds) aggregate gross weight or more of one category of material is loaded at one loading facility. At that threshold, the transport vehicle must be placarded for that category of material as specified in Table 2 of § 172.504(e). For the materials described in your letter in the quantities indicated, the CORROSIVE placard and the DANGEROUS placard satisfy the requirements of the HMR.
For your information, the exceptions in § 172.504(c) do not prohibit the display of
placards according to this subpart, if not otherwise prohibited, on transport vehicles or freight containers that are not required to be placarded [§ 172.502].
I hope this answers your inquiry.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.500(b)(6)