Interpretation Response #09-0224 ([URS] [Ms. Erin N. Jarman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: URS
Individual Name: Ms. Erin N. Jarman
Location State: NC Country: US
View the Interpretation Document
Response text:
October 14, 2009
Ms. Erin N. Jarman
Environmental Scientist
1600 Perimeter Park Drive
Suite 400
Morrisville, NC 27560
Ref. No. 09-0224
Dear Ms. Jarman:
This responds to your October 1, 2009 letter requesting clarification concerning cargo tank marking and placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
Q1. When a cargo tank is cleaned and purged of residue and vapor, may the placard representing the hazardous material previously contained in the cargo tank remain on the vehicle?
A1. No. Section 172.502(a) prohibits the display of placards on any packaging, freight container, unit load device, motor vehicle, or rail car unless the material being offered for transportation or transported is a hazardous material and the placard represents a hazard of the hazardous material being offered or transported.
Q2. When a cargo tank is cleaned and purged of residue and vapor, is it permissible to display four zeros in place of the UN number of the hazardous material previously contained in the vehicle? Or is it correct and preferred to flip the UN number marking section of the placard to display all blanks (i.e., no numerals)?
A2. Section 172.334(b)(3) prohibits the display of a UN identification number unless the vehicle contains the hazardous material associated with that UN identification number. It is the opinion of this Office that using four zeros in lieu of blank spaces in the UN number marking section of a placard could cause confusion for emergency responders in the event of
an incident and, in keeping with the intent of the regulations, is prohibited. Therefore, it would be correct to flip the UN number marking section of the placard to display all blanks (i.e., no numerals).
I hope this answers your inquiry. If you need further assistance, do not hesitate to contact this Office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
172.334, 172.502