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Interpretation Response #12-0206

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

Interpretation Response Details

Response Publish Date: 11-30-2012
Company Name: Ammunition Surveillance Inspector    Individual Name: Mr. David Arange
Location state: CA    Country: US

View the Interpretation Document

Response text:

November 30, 2012



Mr. David Arange
Ammunition Surveillance Inspector
Military Ocean Terminal Concord (MOTCO)
Concord, CA 94520

Reference No. 12-0206

Dear Mr. Arange:

This is in response to your September 11, 2012 letter requesting clarification from the Pipeline and Hazardous Materials Safety Administration (PHMSA) on the requirements for explosive placards on rail cars under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your inquiry relates to placarding of Division 1.1 or 1.2 explosives packaged in 20' shipping containers loaded on flat rail cars. You note that the regulations in § 172.508(a) require placards to be displayed on each freight container. Specifically, you ask if the flat rail cars as shown in the photograph you provided must also display an explosives placard on a white background as required by§ 172.510(a)?

The answer is yes. The placards on the 20' containers do not meet the requirements of 172.510(a). Therefore, the freight containers on a flat rail car, as shown in the picture you provided, must be placarded with the explosives placards on a white background in conformance with §172.510(a).

I hope this satisfies your request.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division



Regulation Sections

Section Subject
§ 172.508 Placarding and affixing placards: Rail