Interpretation Response #10-0247
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name:
Location State: OH Country: US
View the Interpretation Document
Response text:
July 26, 2011
Ms. Laura Grove
Trucking " R & L
600 Gilliam Road
Wilmington, Ohio 45177
Ref. No.: 10-0247
Dear Ms. Grove:
This responds to your e-mail regarding the requirements for display of markings, labels, or placards on shipments of hazardous materials (liquids) in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company has implemented a program that uses an insulating blanket to reduce the risk of hazardous materials freezing. Specifically, you ask if the markings, labels, or placards on the packaging need to be transferred to the outside of the blanket.
The answer is yes. In accordance with Part 172 of the HMR, markings (§172.304), labels (§172.406) and placards (§172.516) must be unobscured and visible. For a bulk packaging contained in or on a transport vehicle or freight container, if the identification number marking on the bulk packaging is not visible, the transport vehicle or freight container must be marked on each side and each end as specified by § 172.332 with the identification number marking.
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Ben Supko
Chief, Standards Development Branch
Standards and Rulemaking Division
172.304, 172.406, 172.516, 172.332