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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 #06-0082 ([3AL Testing Corporation] [Mr. Robert Fick])

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

Interpretation Response Details

Response Publish Date:

Company Name: 3AL Testing Corporation

Individual Name: Mr. Robert Fick

Location State: CO Country: US

View the Interpretation Document

Response text:

Jun 30, 2006

Mr. Robert Fick                 Reference No. 06-0082
3AL Testing Corporation
825 East 73 Avenue
Denver, CO 80229

Dear Mr. Fick:

This is in response to a March 31, 2006 letter we received from your company’s former Vice President, Mr. Paul Graves, and your June 15, 2006 telephone conversation with a member of my staff concerning placarding requirements under the Hazardous Materials Regulations (HMR, 49 CFR Parts 171-180) for transport vehicles containing cylinders filled with flammable and non-flammable gas, and transport vehicles containing empty cylinders with oxygen residue or empty cylinders that no longer contain oxygen and have their valves open. We have paraphrased Mr. Graves’ questions and answered them in the order provided.

Q1. What placarding requirements apply to a transport vehicle with 1,000 pounds or more of non-bulk cylinders containing Division 2.2 (non-flammable) gas and one non-bulk cylinder containing a Division 2.1 (flammable) gas?

Al. A transport vehicle or freight container transported by highway or rail that contains more than 454 kilograms (1,001 pounds) aggregate gross weight of Table 2 hazardous materials in non-bulk packages does not qualify for the exceptions from placarding prescribed in § 172.504(c), and must be placarded for each hazard class it contains. Alternatively, shippers may use the DANGEROUS placard in place of the separate placards specified for each Table 2 material unless 1,000 kg (2,205 pounds) or more aggregate gross weight of one category of hazardous materials in non-bulk packages is loaded at one loading facility. See
§ 172.504(b). For each Table 2 material with a subsidiary hazard, the placards must comply with the provisions in § 172.505 when applicable.

Q2. Under § 172.504(d), are empty medical size E or empty medical size M6/B oxygen cylinders counted as full cylinders for determining whether or not the transport vehicle must be placarded?

A2. Generally, empty packagings containing the residue of a hazardous material must be transported in the same manner as when they previously held a greater quantity of the material unless the packagings are sufficiently cleaned and purged of vapors to remove any potential hazard, or are refilled with a material that is not subject to the HMR. Hazardous materials packages, such as cylinders, that are sufficiently cleaned of residue and purged of vapor to remove any potential hazard are not regulated under the HMR. See § 173.29(b)(2)(ii). An oxygen cylinder is sufficiently cleaned and purged when the vapors in the cylinder are no longer capable of actively supporting combustion and performing as an oxidizing agent.

I hope this information is helpful.



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


Regulation Sections

Section Subject
172.504 General placarding requirements