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Interpretation Response #14-0031 ([YRC Freight, Inc.] [Ms. Susan D. Camara])

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

Interpretation Response Details

Response Publish Date:

Company Name: YRC Freight, Inc.

Individual Name: Ms. Susan D. Camara

Location State: KS Country: US

View the Interpretation Document

Response text:

March 12, 2014

Ms. Susan D. Camara
Safety Manager
YRC Freight, Inc.
1990 Roe Avenue, MS/A340
Overland Park, KS   66211

Ref. No. 14-0031

Dear Ms. Camara:

This responds to your January 27, 2014 request for clarification of the use of the DANGEROUS placard under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).   Specifically, you ask if §§ 172.500(b)(6) and 172.502(c) permit the display of a DANGEROUS placard on a transport vehicle containing two or more categories of non-bulk when one of those commodities is a combustible liquid in a non-bulk package.

In accordance with § 172.504(b), a freight container, unit load device, transport vehicle, or rail car which contains non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of § 172.504(e) may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials.  Section 172.500(b)(6) states that “placarding does not apply to combustible liquids in non-bulk packaging.”  However, § 172.502(c) states “placards may be displayed for a hazardous material, even when not required, if the placarding otherwise conforms to the requirements of this subpart.”   It is your understanding that displaying a DANGEROUS placard on a transport vehicle containing Table 2 Class 3 flammable liquid and Table 2 combustible liquid (both in non-bulk packages) is permissible under the HMR.  

Your understanding is correct.  A COMBUSTIBLE placard is not required for combustible liquids in non-bulk packaging (§ 172.500 (b)(6)). However, a placard may be displayed for a hazardous material, even when not required, provided the placarding is carried out in conformance with Part 172, Subpart F.  Therefore the use of the DANGEROUS placard on a transport vehicle containing Class 3 flammable liquid and combustible liquids, both in non-bulk packages, is authorized under the Part 172, Subpart F provided all other requirements of
§ 172.504(b) are met.

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

Sincerely,

Robert Benedict
Chief, Regulations Development Branch
Standards and Rulemaking Division

172.500, 172.502, 172.504

Regulation Sections

Section Subject
172.500 Applicability of placarding requirements
172.502 Prohibited and permissive placarding
172.504 General placarding requirements