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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 #14-0183 ([Denton Police Department] [Mr. William 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: Denton Police Department

Individual Name: Mr. William Burson

Location State: TX Country: US

View the Interpretation Document

Response text:

December 23, 2014

William Burson
Director, Transportation
Denton Police Department
601 E Hickory St. Ste. E
Denton, Texas 76205

Ref. No.: 14-0183

Dear Mr. Burson:

This responds to your October 3, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking and placarding requirements of transport vehicles containing Intermediate Bulk Containers (IBCs).  Your questions are paraphrased and answered below.

Q1. You provide photographs of an IBC which is labeled in accordance with                              § 172.514(c)(4) and marked with the identification number in accordance with the size requirements of  § 172.302(b)(2).  The IBC is loaded on a trailer and the identification numbers on the IBCs are visible from the front and back of the trailer.  You ask if the identification numbers must additionally be displayed on the transport vehicle in accordance with § 172.331(c)?

A1. The answer is yes.  For an IBC that is labeled instead of placarded, § 172.514(c)(4) allows display of the proper shipping name and identification number in accordance with the size requirements of § 172.302(b)(2) in place of the identification number on an orange panel or placard, or white square-on-point specified in § 172.302(a).

Section 172.331(c) states when the identification number markings on the IBC specified in § 172.302(a) are not visible, the transport must be marked as required by  § 172.332.  In your scenario, the IBC is marked in accordance with § 172.302(b)(2) and not § 172.302(a).  Therefore, the transport vehicle must also be marked with the identification numbers in the appropriate orange panel, placard or white square-on-point configuration as required by § 172.332.  

Q2. You provide a photograph of a “placard tree” where two, double-sided placards are mounted to a post facing opposite directions.  You ask whether this configuration meets the requirements of § 172.504 (a) to be “placarded on each side and each end.”  You further ask whether letters of interpretation Ref. No. 10-0075 and 09-0109 create conflicting guidance with letter of interpretation Ref. No. 13-0086.

A2. The answer to both of your questions is no.  When placarding is required by                  § 172.504 of the HMR, a transport vehicle must be placarded "on each side and each end."  In the scenario you describe, both placards are located on a single end of the transport vehicle.  Therefore, the placards are not applied to each side and each end as required by § 172.504.

The language you reference in letters Ref. No. 10-0075 and 09-0109 addresses the visibility requirements specified in § 172.516.   Both letters describe scenarios where the placards have already met the requirement in § 172.504(a) specifying that they must be adhered to each side and end of the transport vehicle.  The letters discuss whether the specific placement on each side and end meets the visibility requirements further specified in § 172.516.  Letter Ref. No. 13-0086 is the only letter you reference which addresses whether placement of a placard meets the requirement specified in § 172.504(a) for placement of a placard on the sides and ends of a vehicle.  Placards on a transport vehicle must meet the requirements specified in both §§ 172.504 and 172.516.  Therefore, the letters do not provide conflicting guidance.  

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.


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

172.514(c)(4), 172.302(b)(2), 172.331(c), 172.302(a), 172.332, 172.504 (a), 172.504, 172.516,

Regulation Sections

Section Subject
172.302 General marking requirements for bulk packagings.
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
172.332 Identification number markings
172.504 General placarding requirements