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Interpretation Response #07-0081 ([Pilot Chemical Company] [Mr. Matthew J. Leary])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pilot Chemical Company

Individual Name: Mr. Matthew J. Leary

Location State: OH Country: US

View the Interpretation Document

Response text:

Jul 26, 2007

Mr. Matthew J. Leary                 Reference No. 07-0081

Corporate EHS Manager

Pilot Chemical Company

2744 E. Kemper Road

Cincinnati, OH 45241

Dear Mr. Leary:

This is in response to your letter dated April 12, 2007, requesting clarification as to who is responsible to ensure placards are affixed to an isotainer offered for transportation by highway to a rail yard under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the offeror or the carrier has the responsibility to affix placards to the isotainer in the scenario you describe.

As provided by § 172.514, each person who offers for transportation a bulk packaging which contains a hazardous material must affix the placards specified for the material in § 172.504 and 172.505. In addition to the placards required to be placed on a bulk package by the offeror, each person offering a motor carrier a hazardous material for transportation by highway must provide the motor carrier with the required placards for the material being offered prior to or at the same time the material is offered for transportation, unless the carrier"s motor vehicle is already placarded for the material. A motor carrier may not transport a hazardous material in a motor vehicle unless the placards required for the material are affixed to the motor vehicle (see § 172.506).

I hope this information is helpful.

Sincerely,

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

172.514, 172.504, 172.505

Regulation Sections

Section Subject
172.504 General placarding requirements
172.505 Placarding for subsidiary hazards
172.514 Bulk packagings