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Interpretation Response #15-0120 ([Daniels Training Services] [Daniel Stoehr])

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

Interpretation Response Details

Response Publish Date:

Company Name: Daniels Training Services

Individual Name: Daniel Stoehr

Location State: IL Country: US

View the Interpretation Document

Response text:

September 17, 2015

Daniel Stoehr
Daniels Training Services
PO Box 1232
Freeport, IL 61032

Ref. No. 15-0120

Dear Mr. Stoehr:

This is in response to your June 16, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking, labeling, and placarding requirements of transport vehicles containing Intermediate Bulk Containers (IBCs). Your questions are paraphrased and answered below:

Q1.You ask whether an IBC which uses the exception in § 172.514(c)(4) to display the proper shipping name and identification number markings in accordance with the size requirements of § 172.302(b)(2) in place of the identification number marking on an orange panel or placard, or white square-on-point specified in § 172.302(a), when labeling instead of placarding, must display the markings on two or more opposing sides.

A1. The answer is no. Section 172.336(d) permits a bulk packaging that is labeled instead of placarded in accordance with § 172.514(c) to display identification number markings consistent with the non-bulk marking requirements of § 172.301(a)(1). Therefore, the proper shipping name and identification number must only be marked on one side of the package. Additionally, under § 172.331(c), the transport vehicle must also be marked on each side and each end with the identification numbers in the appropriate orange panel, placard or white square-on-point configuration as required by § 172.332.

Q2. You ask whether the requirement to display labels on two opposing sides for an IBC having a volume more than 64 ft in § 172.406(e), requires an additional duplicate marking so that the labels and markings are on the same surfaces of the package in accordance with § 172.406 (a)(1)(ii).

A2. The answer is no. Section 172.406(a)(1) provides an exception for packages requiring duplicate labeling in accordance with paragraph (e) of that section. We note, however, that you may permissively display additional markings.

I hope this satisfies your request.



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


172.514(c)(4), 172.302(a), 172.336(d), 172.514(c), 172.331(c), 172.332, 172.406(e), 172.406 (a)(1)(ii), 172.406(a)(1)

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
172.332 Identification number markings
172.336 Identification numbers; special provisions
172.406 Placement of labels