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Interpretation Response #06-0074 ([Hyundai America Shipping Agency] [Mr. Herb Giles])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hyundai America Shipping Agency

Individual Name: Mr. Herb Giles

Location State: TX Country: US

View the Interpretation Document

Response text:

Aug 10, 2006


Mr. Herb Giles                 Reference No. 06-0074
Manager, Hazardous Materials
Hyundai America Shipping Agency
1425 Greenway Drive, Suite 600
Irving, TX 75038

Dear Mr. Giles:

This is in response to your March 3, 2006 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180) regarding placarding requirements for hazardous material shipments that are being offered for transportation and transported in accordance with the provisions of the International Maritime Dangerous Goods (IMDG) Code. Specifically, you asked if a shipment prepared in accordance with the IMIDG Code must meet the requirements in § 172.516. You also enclosed a copy of a letter (Ref. No. 05-0276) that asked for clarification of the placarding requirements under the HMR. I apologize for the delay in responding and hope it has not caused any inconvenience.

As provided by § 171.12(b), a hazardous material that is packaged, marked, classed, labeled, placarded, described, stowed and segregated, and certified in accordance with the IMDG Code may be offered and accepted for transportation and transported within the United States subject to the conditions and limitations specified in § 171.12 (b)(1) - (22). The IMDG Code does not specifically prohibit wrapping placards over corrugated surfaces. Thus, a shipment prepared in accordance with the IMDG Code need not meet the requirements in § 172.5 16. Our response to the above referenced letter is based on the placarding requirements in Subpart F of the HMR not the IMDG Code.

I trust this satisfies your request.



Edward T. Mazaullo
Director, Office of Hazardous
  Materials Standards

171.12(b), 172.516

Regulation Sections

Section Subject
171.12 North American Shipments
172.516 Visibility and display of placards