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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 #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

Regulation Sections

Section Subject
172.334 Identification numbers; prohibited display
172.502 Prohibited and permissive placarding