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Interpretation Response #11-0197 ([Air Products & Chemicals, Inc.] [Mr. Joe DiGirolamo])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Products & Chemicals, Inc.

Individual Name: Mr. Joe DiGirolamo

Location State: PA Country: US

View the Interpretation Document

Response text:

December 21, 2011

 

 

Mr. Joe DiGirolamo

Dangerous Goods Specialist

Air Products & Chemicals, Inc.

7201 Hamilton Blvd.

Allentown, PA 18195

Ref. No.: 11-0197

Dear Mr. DiGirolamo:

This responds to your August 15, 2011 email seeking clarification of the placarding requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask what markings and placards are required for certain shipments of materials that are poisonous by inhalation that are loaded at one facility and prepared in accordance with the International Maritime Dangerous Goods (IMDG) Code and DOT SP-7835. You provided two examples of common shipments, which I have paraphrased in the following two scenarios:

Scenario 1:

What are the marking and placarding requirements for a motor vehicle containing 3,000 pounds of a Division 2.3, PIH Hazard Zone A material with a subsidiary Division 2.1 hazard; 8,000 pounds of a Division 6.1, PIH Hazard Zone B material with a subsidiary Class 8 hazard; and 500 pounds of a Class 8 material with a subsidiary Class 6.1, PIH Hazard Zone B hazard? You indicated that under the IMDG Code, the Class 8 material does not have a subsidiary hazard.

Scenario 2:

What are the marking and placarding requirements for a motor vehicle containing 1,000 pounds of a Division 2.3, PIH Hazard Zone A material with a subsidiary Division 2.1 hazard; 3,000 pounds of a Division 6.1, PIH Hazard Zone B material with a subsidiary Class 8 hazard; and 500 pounds of a Class 8 material with a subsidiary Class 6.1, PIH Hazard Zone B hazard? You indicated that under the IMDG Code, the Class 8 material does not have a subsidiary hazard.

Section 171.23(b)(10)(iv)(A) specifies the marking, labeling, and placarding requirements for materials poisonous by inhalation transported in accordance with the IMDG Code in a closed transport vehicle or freight container. The section states that a label or placard conforming to the IMDG Code specifications for a "Class 2.3" or "Class 6.1" label or placard may be substituted for the POISON GAS or POISON INHALATION HAZARD label or placard, as appropriate. It further states that a freight container must be marked with the ID number, regardless of the total quantity in the freight container, as specified in § 172.313(c) and placarded as required by subpart F of part 172 of the HMR.

With respect to placarding in both scenarios, the transport vehicle or freight container must be placarded with the POISON GAS, FLAMABLE GAS, POISON INHALATION HAZARD and CORROSIVE placards in accordance with subpart F of part 172. However, a "Class 2.3" or "Class 6.1" placard may be substituted for the POISON GAS or POISON INHALATION HAZARD placard, as appropriate. Also, for domestic transportation, it should be noted, in accordance with §172.504(f)(8), a POISON INHALATION HAZARD placard is not required on a transport vehicle or freight container that is already placarded with a POISON GAS placard.

With respect to marking for non-bulk packagings, § 171.23(b)(10)(iv)(A) requires that the transport vehicle or freight container in both scenarios must be marked on each side and each end as stated in §172.332 or §172.336, with the identification number specified for the hazardous material in the §172.101 table for all three hazardous materials in the shipment, despite the provisions and limitations stated in § 172.313(c).

I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.

Sincerely,

Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

171.23, 172.313, 172.101

Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations