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Interpretation Response #07-0019 ([Hy Yield Bromine Inc.] [Mr. Byver Daniell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hy Yield Bromine Inc.

Individual Name: Mr. Byver Daniell

Location State: DC Country: US

View the Interpretation Document

Response text:

Mar 20, 2007

Mr. Byver Daniell                     
Reference No. 07-0019
Hy Yield Bromine Inc.
4310 National Guard Drive
Plant City, FL 33563-1112

Dear Mr. Daniell:

This is in response to your telephone conversation with a member of my staff and January 26, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding and marking. Your scenario involves a transport vehicle carrying 31,500 pounds of UN 1581, Chloropicrin and methyl bromide mixtures, Division 2.3, in non-bulk packages. The transport vehicle displays a POISON GAS placard, containing the identification number "1581", on each side and each end. You ask if the transport vehicle is required to be marked with the words "INHALATION HAZARD."

The answer is no. Each non-bulk package must be marked "Inhalation Hazard" in association with the required label and shipping name as required by § 172.3 13(a). A transport vehicle containing large quantities of a material poisonous by inhalation in non-bulk packages must be marked, on each side and each end as specified in § 172.332 or § 172.336, with the identification number specified for the hazardous material. See paragraph (c) of § 172.313. The identification number may be displayed on the POISON GAS placard as permitted by § 172.3 32 and 172.334. When the identification number is displayed on the placard, there is no requirement to display the "INHALATION HAZARD" wording on the transport vehicle or across the center of an additional POISON GAS placard.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


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

172.313 (a), 172.336
172.519, 172.540

Regulation Sections

Section Subject
172.313 Poisonous hazardous materials
172.336 Identification numbers; special provisions
172.519 General specifications for placards
172.540 POISON GAS placard