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Interpretation Response #09-0166 ([Georgia Department of Public Safety] [Capt. Bruce Bugg])

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

Interpretation Response Details

Response Publish Date:

Company Name: Georgia Department of Public Safety

Individual Name: Capt. Bruce Bugg

Location State: GA Country: US

View the Interpretation Document

Response text:

August 18, 2009




Capt. Bruce Bugg

Georgia Department of Public Safety

Motor Carrier Compliance Division

P.O. Box 1456

Atlanta, GA 30371

Ref. No. 09-0166

Dear Captain Bugg:

This responds to your e-mail of July 16, 2009, that requests we compare our response made to a January 9, 2007 letter (Ref. No. 06-0271) with the response we made in response to a similar inquiry presented to this Office in a September 8, 2000 letter (Ref. No. 00-0256) regarding the shipping paper and placarding requirements for materials poisonous by inhalation under the HMR (49 CFR; Parts 171-180). Specifically, the inquires pertained to whether the shipping paper requirements of § 172.203(m) and the subsequent placarding requirements of § 172.505 apply to the description "Hydrogen fluoride, anhydrous, UN1052."

Because anhydrous hydrogen fluoride meets the definition of a material poisonous by inhalation (PIH) in § 171.8, shipments of "Hydrogen fluoride, anhydrous, UN1052" must conform to specific shipping paper, package marking, and placarding regulations applicable to PIH materials. Thus, the shipping paper must include the words "Poison " Inhalation Hazard, Zone C" immediately following the shipping description prescribed in § 172.203(m). Further, the package must be marked "Inhalation Hazard" in accordance with § 172.313(a). Additionally, the transport vehicle or freight container must be placarded with a POISON INHALATION HAZARD placard in addition to any other required placards prescribed in § 172.505(a).

We apologize for the contradictory response in this matter. The original September 8, 2000 letter (Ref. No. 00-0256) regarding this matter is correct and remains valid. The specific hazard zone to which a material is assigned and its physical state are not relevant to whether the requirements of §§ 172.203(m) and 172.505(a) apply. Our January 9, 2007 letter (Ref. No. 06-0271) on this matter will be amended accordingly as soon as possible.

I trust this addresses your concerns satisfactorily. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.203, 172.505

Regulation Sections

Section Subject
172.203 Additional description requirements
172.505 Placarding for subsidiary hazards