Interpretation Response #15-0204

Interpretation Response Details

January 08, 2016

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

Ref. No.: 15-0204

Dear Mr. Lesser:

This responds to your October 12, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities. Your questions are paraphrased and answered below:

Q1.  Does a freight container with a quantity of hazardous material that requires placarding also require a limited quantity mark for additional hazardous material?

A1. A freight container that requires placarding is not required to display the limited quantity mark.  When intended for transport by vessel, a freight container containing packages of hazardous material in limited quantities and no other hazardous materials must be marked with the limited quantity mark once on each side and each end of the exterior of the freight container (see § 172.315(a)(2)).

Q2. Is a freight container required to display the limited quantity placard from the point of origin or can the limited quantity mark be applied at the port facility?

A2. When intended for transport by vessel, a cargo transport unit containing only packages of hazardous material in limited quantities must be marked once on each side and each end of the exterior of the unit. Subsequent highway or rail movements of that shipment may choose to utilize domestic exceptions offered by the HMR if the shipment qualifies for the exception. Please note that §§ 171.22(d) and 171.25(a) provide that a hazardous material subject to the requirements of the International Maritime Dangerous Goods (IMDG) Code, that is offered or intended for eventual transportation by vessel, but not subject to the HMR may be transported in the U.S. when described, marked and labeled in accordance with the IMDG code.

I hope this answers your inquiry.  If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.315(a)(2), 171.22(d), 171.25(a)

Regulation Sections