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Interpretation Response #07-0230 ([Pipe Recovery Systems, Inc.] [Mr. Michel Chammas])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pipe Recovery Systems, Inc.

Individual Name: Mr. Michel Chammas

Location State: TX Country: US

View the Interpretation Document

Response text:

February 21, 2008

Mr. Michel Chammas

General Manager

Pipe Recovery Systems Inc.

1462 Brittmoore Road

Houston, Texas 77043

Ref. No.: 07-0230

Dear Mr. Chammas:

This responds to your December 4, 2007 letter requesting clarification of the placarding provisions specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your scenarios involve the application of §§ 172.504 and 172.505. Your questions are paraphrased and answered below.

Q1. What placards are required on a freight trailer transporting less than 1,000 pounds of non-bulk packages that contain a material, UN1746, Bromine Trifluoride, 5.1 (6.1) (8), PG I, Poison Inhalation Hazard Zone B?

A1. Under the HMR, OXIDIZER placards for the primary hazard and POISON INHALATION HAZARD placards are required, as prescribed by §§ 172.504(e) Table 2, and 172.505(a) respectively. The 454 kg (1,001 pounds) exception in § 172.504(c) does not apply to a material that is required to display a subsidiary POISON INHALATION HAZARD placard in accordance with § 172.505(a). As specified in § 172.505(d), display of the CORROSIVE placard for the subsidiary hazard is permissible, but not required.

Q2. What placards are required on the freight trailer specified above in Q1 if a box of Division 1.4G Igniters, weighing less than 5 pounds, is added?

A2. See A1. No additional placards are required. The Division 1.4G material is eligible for the § 172.504(c) placarding exception even when transported on the same transport vehicle with non-bulk packages of a Division 5.1, Poison-Inhalation Hazard material subject to § 172.505.

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.504, 172.505

Regulation Sections

Section Subject
172.504 General placarding requirements
172.505 Placarding for subsidiary hazards