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Interpretation Response #10-0150

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

Interpretation Response Details

Response Publish Date: 09-03-2010
Company Name: Mid-South, Inc    Individual Name: Mr. A B Eargood Brenntag
Location state: KY    Country: US

View the Interpretation Document

Response text:

September 3, 2010




Mr. A B Eargood
Brenntag Mid-South, Inc
1405 Highway 136 West
Henderson, KY 42420

Ref. No.: 10-0150

Dear Mr. Eargood:

This is in response to your July 13, 2010, letter regarding the identification number marking and placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), for a motor vehicle transporting non-bulk packages containing Chlorine, 2.3, UN 1017.

According to your letter, your company was cited for a violation of § 172.505(a). According to the citation, you are required to display on the transport vehicle the Poison Inhalation Hazard placard with the words "Inhalation Hazard" across the center of the placard and the hazard class at the bottom. It is your company"s practice to display the POISON GAS placard as shown in § 172.540 with the UN identification number 1017 across the center and Class 2 at the bottom when transporting chlorine. Additionally you state the chlorine cylinders on the transport vehicle display an INHALATION HAZARD label.

The POISON GAS placard for Division 2.3 materials as displayed in § 172.540 is the correct placard to be displayed when transporting a poison gas such as Chlorine. The text "Inhalation Hazard" shown on the placard is optional; therefore, the UN identification number may be placed across the center of the Class 2 POISON GAS placard to satisfy the UN identification number marking requirement. An additional placard with the words "Inhalation Hazard" across the center is not required.

I hope this information is helpful. If you have further questions, please contact this office.


Ben Supko
Acting Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 172.540 POISON GAS placard