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Interpretation Response #05-0158 ([Georgia Gulf Sulfur] [Mr. Jerry J. Jennett])

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

Interpretation Response Details

Response Publish Date:

Company Name: Georgia Gulf Sulfur

Individual Name: Mr. Jerry J. Jennett

Location State: GA Country: US

View the Interpretation Document

Response text:

Jul 27, 2005


Mr. Jerry J. Jennett                        Reference No. 05-0158
Georgia Gulf Sulfur
P.O. Box 1165
Valdosta, Georgia 31603-1165

Dear Mr. Jennett:

This responds to your letter dated June 28, 2005, regarding the requirements for marking and placarding a shipment of powdered sulfur in 2000 pound super sacks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Domestically, in accordance with Special Provision 30, in § 172.102 of the HMR, a material described as “Sulfur, 9, NA 1350, III”, is not subject to the requirements of the HMR if transported in a non-bulk packaging or if formed to a specific shape (e.g., prills, granules, pellets, pastilles, or flakes).

A CLASS 9 placard is not required in domestic transportation for a Class 9 (Miscellaneous) material. However, a bulk packaging (e.g., 2000 lb. super sack) containing a Class 9 material must display the identification number in accordance with § 172.331. The identification number marking may be displayed on a CLASS 9 placard, an orange panel, or a white square-on-point display configuration (see § 172.332 and
172.504(f)((9)). In addition, for a bulk packaging contained in or on a transport vehicle or a freight container, if the identification number marking is not visible, the transport vehicle or freight container must be marked as required by § 172.332 of each side and each end with the identification number marking for that material (see § 172.331(c)).

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

172.504, 172.516

Regulation Sections

Section Subject
172.504 General placarding requirements
172.516 Visibility and display of placards