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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 #05-0276 ([Mr. John Stolpe])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. John Stolpe

Location State: CA Country: US

View the Interpretation Document

Response text:

Jan 4, 2006

 

Mr. John Stolpe                      Reference No. 05-0276
4007 Marion Way
Long Beach, CA 90807

Dear Mr. Stolpe:

This responds to your letter requesting clarification of the marking and placarding requirements under the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180). You ask if a freight van containing non-bulk packages of a single hazardous material with an aggregate gross weight of 4,000 kg (8,820 lbs.) must be marked with the identification number on each side and each end. You also submitted pictures of placarded freight containers displaying the identification (ID) number on the placards. In each picture, the placards are distorted because of the corrugated background of the freight container and only 2 digits of the ID number are clearly visible. You ask if this limited visibility of the ID numbers is acceptable under the HMR.

In accordance with § 172.301 , a transport vehicle or freight container containing only a single hazardous material in non-bulk packages must be marked on each side and each end with the identification number specified for the hazardous material in the § 172.101 Table. As to your second question, the HMR do not prohibit placards and ID number markings from being placed on a corrugated surface if the placards and markings comply with the visibility and display requirements specified in § 172.516. Specifically, each placard and ID marking must be clearly visible from the direction it faces. As shown in the photographs you submitted, the placards and markings are not clearly visible from the direction they face, thus, they do not conform to the HMR.

I trust this satisfies your request.

Sincerely,

 

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

172.301(a), 172.516

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings
172.516 Visibility and display of placards