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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 #11-0053 ([Department of the Army] [Mr. Joseph Dugan])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Army

Individual Name: Mr. Joseph Dugan

Location State: IL Country: US

View the Interpretation Document

Response text:

July 7, 2011



Mr. Joseph Dugan

Military Surface Deployment and Distribution Command

Department of the Army

Scott Air Force Base, IL 62225

Ref. No. 11-0053

Dear Mr. Dugan:

This responds to Mr. Maham"s March 3, 2011 letter regarding placarding requirements for a freight container system under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and under the International Maritime Dangerous Goods (IMDG) Code. The letter describes a freight container system ("container") consisting of three or four individual units assembled together for ease of handling during intermodal transportation commonly referred to as tricons or quadcons, respectively. The assembled containers (i.e., the tricon or quadcon) form approved containers in accordance with the International Convention on Safe Containers (CSC) as referenced in the definition of a freight container in the International Maritime Dangerous Goods (IMDG) Code and the United States Coast Guard (USCG) regulations (see 49 CFR Part 450). Specifically, the letter includes a request for clarification of the placarding requirement for a tricon or quadcon when the individual units contain a mix of hazardous material classes or when the end units contain a mix of hazardous material classes and an interior unit(s) contains no hazardous material.

The general placarding requirements under the HMR require the individual units containing hazardous material to display placards on each side and each end (see

§ 172.504(a)). In lieu of placarding on all four sides, the HMR authorizes freight containers less than 640 ft3 to display one placard (or label) on the freight container (see

§ 172.512(b)). As described in Mr. Maham"s letter, each individual unit of a tricon or quadcon has a capacity less than 640 ft3, thus, under the HMR, each individual unit containing hazardous material must display a placard (or label) representative of the hazardous material it contains. With regard to IMDG placarding requirements, it is our opinion that the CSC-approved containers (i.e., the assembled tricon or quadcon) described in your letter are essentially compartmented containers, and thus, may be placarded in the same manner as a multiple-compartment tank containing more than one hazardous material. Such a tank must display placards along each side at the positions of the relevant compartments containing a hazardous material (see of the IMDG Code).

Accordingly, a tricon or quadcon displaying placard(s) on each side of an individual unit containing hazardous material satisfies the placarding requirements of both the HMR and the IMDG Code.

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


Ben Supko

Chief, Standards Development Branch

Standards and Rulemaking Division

172.504(a), 172.512(b),

Regulation Sections

Section Subject
172.504 General placarding requirements
172.512 Freight containers and aircraft unit load devices