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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 #08-0175 ([GEO Specialty Chemicals] [Mr. Matt Beasley])

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

Interpretation Response Details

Response Publish Date:

Company Name: GEO Specialty Chemicals

Individual Name: Mr. Matt Beasley

Location State: GA Country: US

View the Interpretation Document

Response text:

July 24, 2008

Mr. Matt Beasley

GEO Specialty Chemicals

701 Wissahickon Avenue

Cedartown, GA 30125

Ref. No. 08-0175

Dear Mr. Kehrli:

This responds to your July 2, 2008 letter requesting clarification of the placarding and labeling requirements for intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the exception from placarding provided in § 172.514(c) would allow the use of labels, rather than placards, on 175 gallon IBCs containing corrosive materials.

In accordance with § 172.514, except as provided in paragraph (c), each person who offers for transportation a bulk packaging that contains a hazardous material must affix the placards specified for the material in §§ 172.504 and 172.505. The bulk packaging placarding exception for IBCs provided in § 172.514(c)(4) excepts an IBC from placarding if it is labeled in accordance with Part 172, Subpart E of the HMR. Therefore, the HMR allow the use of CORROSIVE labels on 175 gallon IBCs containing corrosive materials.

You should also note that an IBC must be marked with an identification number as specified in §§ 172.332 and 172.336. The authorized sizes and options for display of acceptable identification number markings are prescribed in § 172.332. The options include an orange panel, a placard, or a white square-on-point configuration. For an IBC contained in or on a transport vehicle or freight container, if the identification number marking on the IBC is not visible, the transport vehicle or freight container must be marked as required by § 172.332.

I hope this information is helpful. Please contact us if you require additional assistance.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

172.514, 172.332, 172.336

Regulation Sections

Section Subject
172.332 Identification number markings
172.514 Bulk packagings