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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 #12-0066 ([C & W Global] [Mr. Jeff Bailey])

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

Interpretation Response Details

Response Publish Date:

Company Name: C & W Global

Individual Name: Mr. Jeff Bailey

Location State: FL Country: US

View the Interpretation Document

Response text:

June 25, 2012


Mr. Jeff Bailey
Safety Director
C & W Global
703 Hennis Road
Winter Garden, FL 34787

Ref. No. 12-0066

Dear Mr. Bailey:

This responds to your February 17, 2012 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request confirmation that your drivers are not required to have a hazardous materials (HM) endorsement to their commercial driver"s licenses (CDLs) in order to transport your slag material, "Environmentally hazardous substance, solid, n.o.s., (contains lead), Class 9, UN 3077, PG III, RQ 10."

In accordance with § 172.504(f)(9), placarding is not required for transportation of Class 9 material when shipped domestically. However, a bulk packaging must be marked with the appropriate identification number, and the number may be display on either a Class 9 placard, an orange panel, or a white square-on-point configuration. While the HMR allow display of the identification number on a Class 9 placard, use of this configuration does not make your drivers subject to the endorsement requirement under 49 CFR 383.93 of the Federal Motor Carrier Safety Regulations (FMCSR).
For purposes of the CDL HM endorsement, the term "Hazardous Materials" is defined in 49 CFR § 383.5 as a material that has been designated as hazardous under 49 U.S.C. 5103 and is required to be placarded under subpart F of 49 CFR part 172 or any quantity of a material listed as a select agent or toxin in 42 CFR part 73. Therefore, pursuant to the FMCSR, a driver of a commercial motor vehicle transporting a Class 9 hazardous material that is excepted from placarding for domestic transportation, is not required to obtain a hazardous materials endorsement to his or her CDL.

I hope this answers your inquiry. If you need additional assistance, please contact this office at 202-366-8553.


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.504 General placarding requirements