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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