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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 #13-0206 ([Commerical Motor Vehicle Roadside Inspection] [Mr. William Scott Burson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Commerical Motor Vehicle Roadside Inspection

Individual Name: Mr. William Scott Burson

Location State: TX Country: US

View the Interpretation Document

Response text:

June 5, 2014

Mr. William Scott Burson
Crash Investigator
Commercial Motor Vehicle Roadside Inspection
Denton Police Department
601 E Hickory St., Suite E
Denton, TX 76205

Reference No. 13-0206

Dear Mr. Burson:

This is in response to your October 31, 2013 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to identification numbers on Intermediate Bulk Containers (IBCs). In your scenario, a 500 gallon IBC containing a Class 8 corrosive liquid is transported on an open-sided flatbed truck. The IBC has the correct United Nations (UN) identification number on orange panels on two opposing sides in accordance with §172.302(a)(2). These identification numbers are viewable from either side of the flatbed. You ask if the flatbed is also required to display the UN identification numbers on the front and rear of the vehicle.

The answer is no. The provisions for additional markings in 172.331(c) do not apply because the identification numbers on the IBC are visible. Therefore, as prescribed in §172.302(a), bulk packages with a capacity of less than 1,000 gallons capacity are required to display identification numbers only on two opposing sides. For bulk packages of 1,000 gallons capacity or more, identification numbers must be displayed on all four sides.

I hope this satisfies your request.


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

172.302, 172.331

Regulation Sections

Section Subject
172.302 General marking requirements for bulk packagings.
172.331 Bulk packagings other than portable tanks, cargo tanks, tank cars and multi-unit tank car tanks