Interpretation Response #06-0143 ([Georgia Department of Public Safety] [Captain Bruce Bugg ])

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

Interpretation Response Details

Response Publish Date: 07/28/2006

Company Name: Georgia Department of Public Safety

Individual Name: Captain Bruce Bugg 

Location State: GA Country: US

View the Interpretation Document

Response text:

Jul 28, 2006

Captain Bruce Bugg                 Reference No. 06-0143
Georgia Department of Public Safety
Motor Carrier Compliance Division
P.O. Box 1456
Atlanta, GA 30371-1456

Dear Captain Bruce Bugg:

This is in response to your letter dated June 29, 2006, regarding the placarding
requirements for combustible liquids in intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you
request clarification of a previous letter from PHMSA to a Mr. Paul M. Bomgardner, dated August 14, 1995. Your questions are summarized and answered below.

Q1. A shipper offers an IBC filled with “Combustible liquid, n.o.s.” Must the
shipper placard the IBC, since there is no specified “Combustible liquid” label in the HMR?

Al. The answer is yes. Combustible liquids transported in a bulk packaging must be placarded. A bulk packaging placarding exception authorized in § 172.514(c) allows an IBC to be placarded on two opposing sides or, alternatively, labeled in accordance with Part 172, Subpart E of the HMR. However, because there is no “Combustible liquid” label specified in the HMR, this exception is not authorized for a bulk packaging containing a combustible liquid.

Q2. May the shipper use a label of the same size, shape and design as a
“Flammable liquid” label and replace the word “Flammable” with “Combustible”?

A2. The answer is no. Combustible liquids transported in a bulk packaging must be placarded. A bulk packaging placarding exception authorized in § 172.514(c) allows an IBC to be placarded on two opposing sides or, alternatively, labeled in accordance with Part 172, Subpart E of the HIMIR. However, because there is no “Combustible liquid” label specified in the HIVIR, this exception is not authorized for a bulk packaging containing a combustible liquid.

Q3. May the shipper use “Flammable” placards in place of “Combustible” placards displayed on the IBC?

A3. The answer is no. In accordance with § 172.504(t)(2) a “FLAMMABLE”
placard may only be used in place of a “COMBUSTIBLE” placard on a cargo tank, portable tank or a compartmented tank car which contains both flammable and combustible liquids. This provision does not apply to IBCs.

Q4. May a carrier transporting IBCs use “Flammable” placards on the outside of a closed vehicle (van-type trailer or truck) in place of the “Combustible” placards?

A4. The answer is no. (See response to Q3 above.)

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

Sincerely,

Charles E. Betts
Senior Transportation Specialist
Office of Hazardous Materials Safety

172.504(f) (2), 172.514 (c)

Regulation Sections