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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 #06-0004 ([Department of the Air Force] [TSgt. Jesse Rubalcaba])

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 Air Force

Individual Name: TSgt. Jesse Rubalcaba

Location State: PA Country: US

View the Interpretation Document

Response text:

Jan 24, 2006

TSgt. Jesse Rubalcaba                      Reference No. 06-0004

Command Section Evaluator

Department of the Air Force


6610 Headquarters Drive

F.E. Warren AFB, WY 82005-3943

Dear TSgt. Rubalcaba

This is in response to your letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the exception from placarding in § 172.504(c), for less than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by Table 2 of 172.504(e), applies to the Division 2.2 material in cylinders. You indicate that the cylinders are loaded on a single transport vehicle and weigh approximately 4,800 pounds.

The placarding exception in § 172.504(c) applies to the aggregate gross weight of all non- bulk packagings on a single transport vehicle that are covered by Table 2 of

§ 172.504(e) and do not fall under the provisions of 172.505. As defined in § 171.8,

the phrase "gross weight" is the weight of a packaging plus the weight of its contents.

In your scenario, the aggregate gross weight is equivalent to the aggregate weight of all cylinders and the Division 2.2 material they contain. Therefore, given that the aggregate gross weight of your cylinders is approximately 4,800 pounds, the transport vehicle must be placarded.

I hope this information is helpful. Please contact us if you require additional assistance.



John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.504 General placarding requirements