Interpretation Response #17-0119
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
August 3, 2018
Mr. Andrei Lazourenko
Atlantic Ro-Ro Carriers, Inc.
95 River Street, 3rd Floor
Hoboken, NJ 07030
Reference No. 17-0119
Dear Mr. Lazourenko:
This letter is in response to your September 28, 2017, October 16, 2017, and October 26, 2017, emails requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of enlarged labels in place of placards. You describe the following scenario:
- Your company transports containers of Class 7 (radioactive) material in conformance with the International Maritime Dangerous Goods (IMDG) Code by vessel from international locations to the United States. Enlarged labels on these containers display the applicable radioactive Category Group, activity level, transport index, etc., of the Class 7 material they contain.
- A trucking company that arranges U.S. Territory inland transport of these containers requires the enlarged labels be replaced with Class 7 placards that comply with § 172.556. This placard image does not include a radioactive Category Group or transport index.
Specifically, you ask if enlarged labels that comply with section 188.8.131.52.5.1 in the IMDG Code may remain on containers of Class 7 material transported by vessel to the United States for eventual transportation within the United States by motor vehicle.
The answer is yes. Section 172.519(f) authorizes the use of placards conforming to the specifications in the IMDG Code in place of a corresponding placard conforming to the requirements in 49 CFR Part 172, Subpart F (except for materials poisonous by inhalation).
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.556, 172.519(f), 172
|HAZARDOUS MATERIALS TABLE, SPECIAL PROVISIONS, HAZARDOUS MATERIALS COMMUNICATIONS, EMERGENCY RESPONSE INFORMATION, TRAINING REQUIREMENTS, AND SECURITY PLANS||HAZARDOUS MATERIALS TABLE, SPECIAL PROVISIONS, HAZARDOUS MATERIALS COMMUNICATIONS, EMERGENCY RESPONSE INFORMATION, TRAINING REQUIREMENTS, AND SECURITY PLANS|