Interpretation Response #07-0171 ([4th ID-Fort Carson G3/IMT] [Mr. Len Hammond])

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

Interpretation Response Details

Response Publish Date: 10/16/2007

Company Name: 4th ID-Fort Carson G3/IMT

Individual Name: Mr. Len Hammond

Location State: AL Country: US

View the Interpretation Document

Response text:

Mr. Len Hammond                                  Ref. No. 07-0171

4th ID-Fort Carson

G3/IMT

1675 Long Street

Bldg. 1117, Room 207

Fort Carson, CO 80913-4138

Dear Mr. Hammond:

This responds to your August 31, 2007 letter requesting clarification of the placarding requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification on the use of the DANGEROUS placard under §172.504(b) for your scenarios. Your questions are paraphrased and answered as follows:

Q1: A transport vehicle or freight container is loaded with 1,200 kg of Class 3 flammable liquids; 200 kg Division 6.1 poison material (not an inhalation hazard); and 300 kg Class 8 corrosive material. There are no subsidiary hazard classes. May we apply the Class 3 FLAMMABLE LIQUID placard for Item 1 and the DANGEROUS placard for Items 2 and 3?

A1: Yes. Placards are required because the aggregate gross weight (1,700 kg) of the Class 3, Division 6.1, and Class 8 hazardous materials exceeds 454 kg (1,001 lb). As provided in §172.504(b), the DANGEROUS placard may be substituted for the POISON AND CORROSIVE placards. The FLAMMABLE LIQUID placard must be used for the Class 3 material since it exceeds 1,000 kg (2,205 lb) loaded at one facility.

Q2: A transport vehicle or freight container is loaded with 500 kg Division 6.1 poison material (not an inhalation hazard); 200 kg Class 3 flammable liquid; and 100 kg Class 8 material. May we apply only the DANGEROUS placard?

A2: Yes. The DANGEROUS placard may be used to cover all three Table 2 hazardous materials.

Q3: A transport vehicle or freight container is loaded with 50 kg Division 6.1 poison material (not an inhalation hazard); 200 kg Class 3 flammable liquid; and 100 kg Class 8 corrosive material. Are placards required?

A3: No. Since the aggregate gross weight of all three Table 2 materials is less than 454 kg (1,001 lb), no placards are required.

Q4: A transport vehicle or freight container is loaded with 1,200 (exceeds 2,205 lb) Class 3 flammable liquid; and 200 kg Division 6.1 poison material (not an inhalation hazard). Is the Class 3 FLAMMABLE LIQUID the only placard required?

A4: No. The FLAMMABLE LIQUID placard is required because 1,000 kg of Class 3 material has been loaded at one facility. However, because the entire aggregate gross weight of hazardous materials on the transport vehicle exceeds 454 kg, either the DANGEROUS placard or POISON placard must be used for the Division 6.1 material.

I hope this answers your inquiry.

Sincerely,

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

172.504(b)

Regulation Sections