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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 #13-0026 ([FedEx Freight, Inc.] [Mr. Mike Brust, CDS])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Freight, Inc.

Individual Name: Mr. Mike Brust, CDS

Location State: AZ Country: US

View the Interpretation Document

Response text:

March 5, 2013



Mr. Mike Brust, CDS
Manager, Corporate Safety
FedEx Freight, Inc.
2200 Forward Drive
Harrison, AR   72601

Ref. No. 13-0026

Dear Mr. Brust:

This responds to your January 25, 2013 request for clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask for clarification on the use of the DANGEROUS placard in § 172.504 for two specific shipments.

In your letter, you describe a shipment of 2,337 pounds of non-bulk cylinders of UN 1013, compressed gas, Division 2.2, (non-flammable gas) loaded at one facility, and 1,269 pounds of non-bulk pails of UN 1263, Class 3, flammable liquids placed on a trailer.  You ask if a NON-FLAMMABLE GAS placard and a DANGEROUS placard on the trailer comply with § 172.504 requirements?

The answer to your question is yes.  Section 172.504(b) specifies that a transport vehicle containing non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of this section may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in table 2 of paragraph (e) of this section.  However, when 1,000 kg (2,205 pounds) aggregate gross weight or more of one category of material is loaded at one loading facility, the placard specified in table 2 of paragraph (e) of this section for that category must be applied.  Based on the scenario you describe, the NON-FLAMMABLE gas placard must be displayed and either the DANGEROUS or FLAMMABLE LIQUID placard may represent the flammable liquid.

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