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Interpretation Response #09-0171 ([Carus Corporation] [Mr. Chithambarathanu Pillai])

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

Interpretation Response Details

Response Publish Date:

Company Name: Carus Corporation

Individual Name: Mr. Chithambarathanu Pillai

Location State: IL Country: US

View the Interpretation Document

Response text:

January 27, 2010

 

 

Mr. Chithambarathanu Pillai

Carus Corporation

1500 Eighth Street

La Salle, IL 61201

Ref. No.: 09"0171

Dear Mr. Pillai:

This responds to your July 29, 2009 letter regarding the placarding and marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180). Please accept my apology for our delay in responding and any inconvenience it may have caused. Your questions are summarized and answered below.

Q1. A closed transport vehicle contains multiple bulk packages (tote bins) of UN 1490, 5.1, Potassium permanganate and UN 3214, 5.1, Permanganates, inorganic, aqueous solution, n.o.s. Is it permissible to affix the OXIDIZER placard along with orange identification number panels displaying "1490" and "3214"? Also, is it permissible to affix the OXIDIZER placard with the ID number 3214 and a separate OXIDIZER placard with ID number 1490 instead?

A1. Yes. The vehicle must be placarded when transporting a bulk package as required by § 172.504(a) and must display an ID number on all four sides as required by §172.302(a). The transport vehicle may be marked and placarded with four OXIDIZER placards displaying the ID numbers "1490" and "3214" or four orange panels displaying the ID numbers "1490" and "3214" and four OXIDIZER placards.

Q2. A truck is loaded with one (bulk package) tote bin containing UN 1490, 5.1, Potassium permanganate and 10,000 pounds of UN 3214, 5.1, Permanganates, inorganic, aqueous solution, n.o.s in non-bulk packages. What placarding and ID number markings are required?

A2. The bulk package containing the potassium permanganate, UN 1490, must be marked and placarded as discussed in answer A1 above. A vehicle transporting 10,000 pounds of permanganates, inorganic, aqueous solution, n.o.s., UN 3214, in non-bulk packages must display OXIDIZER placards in accordance with §172.504. In addition, if 8,820 pounds or more of the permanganates, inorganic, aqueous solution, n.o.s, is loaded at a single loading facility, the transport vehicle must be marked on each side and each end as specified in § 172.301(a)(3). See §§ 172.332 and 172.336.

Q3. A truck is loaded with one bulk package (tote bin) containing UN 3214, 5.1, Permanganates, inorganic, aqueous solution, n.o.s. and 10,000 pounds of UN 1490, 5.1 Potassium permanganate. What placarding and ID number markings are required?

A3. The bulk package containing permanganates, inorganic, aqueous solution, n.o.s., UN 3214, must be marked and placarded as discussed in answer A1 above. A vehicle transporting 10,000 pounds of potassium permanganate, UN 1490, in non-bulk packages must display OXIDIZER placards in accordance §172.504. In addition, if 8,820 pounds or more of the potassium permanganate is loaded at a single loading facility, the transport vehicle must be marked on each side and each end as specified in § 172.301(a)(3). See §§ 172.332 and 172.336.

Q4. A truck is loaded with one (bulk package) tote bin containing UN 1490, 5.1 Potassium permanganate and 2,000 pounds of UN 3214, 5.1, Permanganates, inorganic, aqueous solution, n.o.s. What placarding and ID number markings are required?

A4: The bulk package containing potassium permanganate, UN 1490, must be marked and placarded as discussed in answer A1 above. A vehicle transporting 2,000 pounds of permanganates, inorganic, aqueous solution, n.o.s., UN 3214, in non-bulk packages must display OXIDIZER placards in accordance §172.504. ID number marking is not required for non-bulk shipments of permanganates, inorganic, aqueous solution, n.o.s., UN 3214, under 8,820 pounds. See §172.301(a)(3).

Q5. A truck is loaded with one (bulk package) tote bin of UN 3214, 5.1, Permanganates, inorganic, aqueous solution, n.o.s. and 2,000 pounds of UN 1490, 5.1 Potassium permanganate. What placarding and ID number markings are required?

A5: The bulk package containing permanganates, inorganic, aqueous solution, n.o.s,, UN 3214, must be marked and placarded as discussed in answer A1 above. A vehicle transporting 2,000 pounds of potassium permanganate, UN 1490, in non-bulk packages must display OXIDIZER placards in accordance §172.504. ID number marking is not required for non-bulk shipments of potassium permanganate, UN 1490, under 8,820 pounds. See § 172.301(a)(3).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.504, 172.301(a)(3), 172.332 and 172.336

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings
172.332 Identification number markings
172.336 Identification numbers; special provisions
172.504 General placarding requirements