Interpretation Response #11-0032

Interpretation Response Details

June 9, 2011

Ms. Lisa Taylor
RSLP, TASC Inc.
Hill AFB, B1267 West Side, UT

Reference No. 11-0032

Dear Ms. Taylor,

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display of identification numbers on Class 1 (explosive) placards. Specifically, you request confirmation of your understanding that motor vehicles may not display identification numbers on placards with for Division 1.1 and 1.3 (explosive) materials.

The limitations pertaining to the display of identification numbers (see § 172.503) on placards are set forth in § 172.334. Section 172.334(a) prohibits the display of an identification number on certain placards, including EXPLOSIVES 1.1, 1.2, 1.3, 1.4, 1.5 and 1.6 placards. However, as specified in § 172.336(b), for materials in hazard classes for which placards are specified and identification number displays are required, but for which identification numbers may not be displayed on the placards authorized for the material, identification numbers must be displayed on orange panels or on the plain white square-on-point display configuration in association with the required placards. An identification number displayed on a white square-on-point display configuration is not considered to be a placard.

I hope this information is helpful. Please contact this Office should you need additional assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.336(b), 172.334, 172.503

Regulation Sections