USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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.

Sincerely,

 

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