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Interpretation Response #09-0201 ([Hazmat, Inc.] [Mr. Paul J. Dambek])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazmat, Inc.

Individual Name: Mr. Paul J. Dambek

Location State: NH Country: US

View the Interpretation Document

Response text:

October 1, 2009



Mr. Paul J. Dambek

Hazmat, Inc.

12 Kimball Hill Road

Hudson, NH 03051-3915

Ref. No.: 09"0201

Dear Mr. Dambek:

This responds to your August 14, 2009 letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180). Your questions are paraphrased and answered below.

Q1. A shipper offers for transportation two cylinders of Chlorine, UN1017, 2.3 (5.1, 8). The gross weight of this shipment is 800 pounds. Must the vehicle be placarded with the poison gas, oxidizer, and corrosive placards?

A1. No. The required placard for "UN1017, Chlorine, 2.3" is the POISON GAS placard. See § 172.504(e), Table 1. Placarding for the subsidiary 5.1 and 8 hazards is not required, but is permissible as specified in § 172.505. The HMR do not specify how to display the primary and subsidiary placards in relation to each other; however, each placard must be clearly visible from the direction it faces.

Q2. A shipper offers for transportation two cylinders containing residual amounts of Chlorine, UN1017, 2.3 (5.1, 8). Is the shipment required to be placarded?

A2. Yes. As specified in § 173.29, empty packagings containing the residue of a hazardous material must be offered and transported in the same manner as when they previously contained a greater quantity of the hazardous material unless the packagings are sufficiently cleaned of residue and purged of vapors to remove any potential hazard, or are refilled with a material that is not subject to the HMR.

Q3. A shipper offers for transportation a drum of Chlorosulfonic acid, UN1754, 8 (6.1), PG I for transportation by highway. The gross weight of the material is 450 pounds. Is the shipment required to be placarded?

A3. Yes. In accordance with § 172.505(a), a poisonous material subject to the "Poison Inhalation Hazard" shipping description requirements in § 172.203(m) must be placarded with a POISON INHALATION HAZARD or POISON GAS placard. Chlorosulfonic acid meets

the definition for a material that is poisonous by inhalation (see Special Provision 2 as indicated in Column 7 for the entry for Chlorosulfonic acid in the Hazardous Materials Table in § 172.101) and, therefore, is subject to the shipping description requirements in § 172.203(m) and the placarding requirements in § 172.505(a).

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.505, 173.29, 172.101

Regulation Sections

Section Subject
172.203 Additional description requirements
172.505 Placarding for subsidiary hazards
173.29 Empty packagings