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Interpretation Response #11-0298

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

Interpretation Response Details

Response Publish Date: 01-30-2012
Company Name: Public Utilities Commission of Ohio Transportation Department Compliance Division    Individual Name: Mr. Tom Forbes
Location state: OH    Country: US

View the Interpretation Document

Response text:

January 30, 2012



Mr. Tom Forbes
Public Utilities Commission of Ohio
Transportation Department
Compliance Division
180 East Broad Street, 4th Floor
Columbus, Ohio 43215-3793

Ref No. 11-0298

Dear Mr. Forbes:

This responds to your November 28, 2011 request for clarification on placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, a carrier is transporting "UN 278l9, Acetic acid solution, 8, (3), PG II, Ltd Qty" and "UN 3265, Corrosive liquid, acidic, organic, n.o.s, 8, PG II (corrosive liquid), Ltd Qty" in a quantity over 1,000 pounds. You ask if it is permissible to placard the vehicle with Class 3
FLAMMABLE placards for the subsidiary hazard and display no other placards for the primary hazard.

The answer to your question is no. Given that you are shipping limited quantities, placarding is not required (§ 172.500(b)(3)). However, if you choose to placard you may do so in accordance with § 172.502(c). Placarding must be in conformance with § 172.504, based on the placarding tables in paragraph (e) of that section. For the example presented, the CORROSIVE placard would be displayed. In addition to the CORROSIVE placards, you may placard for subsidiary hazards in accordance with § 172.505(d).

I hope this answers your inquiry.


Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division

172.502, 172.505(d)

Regulation Sections

Section Subject
§ 172.502 Prohibited and permissive placarding