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Interpretation Response #05-0168 ([Department of the Army] [Mr. Charles R. Schulz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Army

Individual Name: Mr. Charles R. Schulz

Location State: OK Country: US

View the Interpretation Document

Response text:

Dec 13, 2005

 

Mr. Charles R. Schulz                      Reference No. 05-0168
HAZMAT Team Leader
Department of the Army
Defense Ammunition Center
1 C Tree Road
McAlester, OK 74501

Dear Mr. Schulz:

This is in response to your July 8, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding requirements. You present a number of scenarios with your interpretation of placarding requirements. All scenarios are non-bulk shipments. You ask that we comment on the accuracy of your interpretation. Your specific scenarios and interpretations, and our responses are as follows:

Scenario #1:      4,000 kg of Class 3 (Flammable) material, 200 kg of Class 8 (Corrosive) material, and 200 kg of Class 4.1 (Flammable Solid) material are loaded onto one truck. There are no subsidiary hazardous classes.

Schulz interpretation: You suggest that the “FLAMMABLE” placard is required.

PHMSA comment:       As specified in § 172.504(c)(1), “FLAMMABLE,” “CORROSIVE,” and “FLAMMABLE SOLID” placards are required because the aggregate gross weight (4,400 kg) of the Class 3, Class 8, and Class 4.1 hazardous materials exceeds 454 kg (1,001 lb). However, as provided in § 172.504(b), the “DANGEROUS” placard may be substituted for the “CORROSIVE” and “FLAMMABLE SOLID” placards.

Scenario #2:      4,000 kg of Class 3 (Flammable) material, 400 kg of Class 8 (Corrosive) material, and 200 kg of Class 4.1 (Flammable Solid) material are loaded onto one truck. There are no subsidiary hazardous classes.

Schulz interpretation: You suggest that the “FLAMMABLE” and ‘DANGEROUS”                  
                                 Placards are required.

PHMSA comment:      The “FLAMMABLE,” “CORROSIVE,” and “FLAMMABLE SOLID” placards are required because the aggregate gross weight (4,600 kg) of the Class 3, Class 8, and Class 4.1 hazardous materials exceeds 454 kg (1,001 lb). The placarding exceptions provided in § 172.504(c) may not be used because the Class 3 material exceeds 454 kg (1,001 lb). However, as provided in § 172.504(b), the “DANGEROUS” placard may be substituted for the “CORROSIVE” and “FLAMMABLE SOLID” placards.

Scenario #3:      175 kg of Class 8 (Corrosive) material with a subsidiary hazard class of Class 6.1 (Poison Inhalation Hazard) Zone B, 300 kg of Class 3 (Flammable) material, and 25 kg of Class 5.1 (Oxidizer) material are loaded onto one truck. The Class 3 and Class 5.1 hazardous materials do not have subsidiary hazards.

Schulz interpretation: You suggest that the “CORROSIVE” and “POISON   INHALATION HAZARD” placards are required.

PHMSA comment:      The “CORROSIVE” and POISON INHALATION HAZARD” placards are required. The weight of Table 2 materials in non-bulk packagings which are required, under the provisions of § 172.505(a), to be placarded with “POISON INHALATION HAZARD” or “POISON GAS” placards are not included in determining the aggregate gross weight of hazardous materials covered by Table 2, for purposes of eligibility for the exception in § 172.504(c). Therefore, as provided in § 172.504(c), the “FLAMMABLE” and “OXIDIZER” placards are not required because the aggregate gross weight of the Class 3 and Class 5.1 materials is less than 454 kg. However, as provided in
§ 172.504(b), the “DANGEROUS’ placard may be substituted for the “CORROSIVE” placard.

Scenario #4:     1,250 kg of Class 3 (Flammable) material with a subsidiary hazard class of Class 6.1 (Poison Inhalation Hazard) Zone B hazardous material, 275 kg of Class 2.1 (Flammable Gas) material, and 200 kg of Class 4.1 (Flammable Solid) material, are loaded onto one truck. The Class 2.1 and Class 4.1 hazardous materials do not have subsidiary hazards.

Schulz interpretation: You suggest that the “FLAMMABLE,” “POISON INHALATION
HAZARD,” and “DANGEROUS” placards are required.

PHMSA comment:      The “FLAMMABLE,” “POISON INHALATION HAZARD,” “FLAMMABLE GAS,” and “FLAMMABLE SOLID” placards are required. However, as provided in § 172.504(b), the
“DANGEROUS’ placard may be substituted for the “FLAMMABLE GAS” and “FLAMMABLE SOLID” placards.

Scenario #5:      650 kg of Class 8 (Corrosive) material with a subsidiary hazard class of Class 6.1 (Poison Inhalation Hazard) Zone B material, 675 kg of Class 3 (Flammable) material, and 875 kg of Class 4.1 (Flammable Solid) material, are loaded onto one truck. The Class 3 and Class 4.1 hazardous materials do not have subsidiary hazards.

Schulz interpretation: You suggest that the “DANGEROUS” and “POISON      
                                 INHALATION HAZARD” placards are required.

PHMSA comment:       The “CORROSIVE,” “POISON INHALATION HAZARD,”  “FLAMMABLE,” and “FLAMMABLE SOLID” placards are required. However, as provided in § 172.504(b), the “DANGEROUS’ placard may be substituted for the “CORROSIVE,” “FLAMMABLE,” and “FLAMMABLE SOLID”
placards.

I trust this satisfies your inquiry.

Sincerely,

 

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.504

Regulation Sections

Section Subject
172.504 General placarding requirements