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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 #15-0034 ([Crowley Liner Service] [Mr. Michael Lesser])

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

Interpretation Response Details

Response Publish Date:

Company Name: Crowley Liner Service

Individual Name: Mr. Michael Lesser

Location State: FL Country: US

View the Interpretation Document

Response text:

July 09, 2015

Mr. Michael Lesser
Crowley Liner Service
9487 Regency Square Blvd
Jacksonville, FL 32225

Reference No. 15-0034

Dear Ms. Lesser:

This is response to your February 11, 2015 e-mail and subsequent conversations with members of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. In your letter, you state that your driver receives a loaded intermodal container that is exempt from placarding under § 172.504 but loses the exception by vessel. You ask whether the driver loses the ability to use the exception for placarding by highway if his destination is a port, or may the driver apply the placard (required for vessel transportation) after leaving public roads but prior to entering the port.

Shipments of non-bulk combustible materials do not require placards as specified in § 172.504 when shipped under the HMR. However, the HMR does not prevent the use of placards when shipping non-bulk shipments of combustible materials provided the placards appropriately represent the hazard classes being shipped. If placards are required for vessel transportation for a hazardous material that does not require a placard for highway transportation, the placards could be placed on the container at the port prior to transportation by vessel.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
172.504 General placarding requirements