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Interpretation Response #11-0283 ([R & L Carriers, Inc.] [Mr. Gerald A. Krisa])

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

Interpretation Response Details

Response Publish Date:

Company Name: R & L Carriers, Inc.

Individual Name: Mr. Gerald A. Krisa

Location State: OH Country: US

View the Interpretation Document

Response text:

February 1, 2012



Mr. Gerald A. Krisa
Vice President of Safety
R & L Carriers, Inc.
P.O. Box 271
Wilmington, OH 45177

Ref. No. 11-0283

Dear Mr. Krisa:

This responds to your October 10, 2011 letter regarding the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods Code (IMDG). Specifically, you ask if a corrosive placard conforming to the specifications of the IMDG Code may be used for transportation of hazardous materials solely within the United States.

The answer is yes, provided all or part of the movement is by vessel. Section 171.25(a) states that a hazardous material may be offered for transportation or transported to, from or within the United States by vessel, and by motor carrier and rail in accordance with the IMDG Code, as authorized in § 171.22, provided all or part of the movement is by vessel. Further, § 172.502(b), which pertains to permissive placarding, excepts placards that conform to the IMDG Code from the prohibited placarding specified in § 172.502(a).

Recently we were made aware that the requirement for all or part of the movement to be by vessel may impede shipments of hazardous materials that originate from foreign countries. We intend to address this issue in a future rulemaking.

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

171.22, 171.25, 172.502

Regulation Sections

Section Subject
171.22 Authorization and conditions for the use of international standards and regulations
171.25 Additional requirements for the use of the IMDG Code
172.502 Prohibited and permissive placarding