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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 #07-0102 ([Medical Services of America] [Mr. Wayne R. Cromley])

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

Interpretation Response Details

Response Publish Date:

Company Name: Medical Services of America

Individual Name: Mr. Wayne R. Cromley

Location State: SC Country: US

View the Interpretation Document

Response text:

Jun 25, 2007


Mr. Wayne R. Cromley                 Reference No. 07-0102
Corporate Safety & Risk Management Director
Medical Services of America
171 Monroe Lane
P.O. Box 1928
Lexington, South Carolina 29071

Dear Mr. Cromley:

This is in response to your May 8, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification on the placarding requirements under § 172.504 when transporting a non flammable gas such as, “Oxygen, refrigerated liquid ( liquid) 2.2, UN 1073” in a packaging that has the capacity to hold 200 liters/777 pounds of liquid. Additionally, you ask whether the packaging qualifies as a bulk packaging in accordance with the definition for “bulk packaging” in § 171.8.

The answer to both questions is no. As provided by § 172.504(c), except for bulk packagings and hazardous materials subject to § 172.505, a transport vehicle carrying less than 454 kg (1,001 pounds) aggregate gross weight (packaging plus contents) of Table 2 hazardous materials need not be placarded. When calculating the 454 kg (1,001 pounds) aggregate gross weight, only the weight of Table 2 hazardous materials in non-bulk packaging needs to be included. A non-bulk packaging, as defined in § 171.8 means a packaging which has a maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid. As stated in your letter, your container has a maximum capacity of 200 L (52.8 gallons) therefore your container would be considered a non-bulk packaging and not a bulk packaging.

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



Charles F. Betts
Senior Transportation Specialist
O of Hazardous Materials Standards

171.8, 172.504

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.504 General placarding requirements