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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 #18-0094

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

Interpretation Response Details

Response Publish Date:

Company Name: DG Advisor, LLC

Individual Name: Ben Barrett

Location State: WY Country: US

View the Interpretation Document

Response text:

February 25, 2019

Ben Barrett
DG Advisor, LLC
P.O. Box 248
Dubois, WY  82513

Reference No. 18-0094

Dear Mr. Barrett:

This letter is in response to your June 20, 2018, email and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of hazardous materials in the same overpack together with materials not meeting the definition of a hazardous material. 

We have paraphrased and answered your questions as follows:

Q1.  You ask if a non-hazardous material can be placed in an overpack that contains a hazardous material package.

A1. The answer is yes.  The HMR do not prescribe requirements or limitations for non-hazardous material packed in an overpack; therefore, there is no prohibition from including hazardous and non hazardous material in an overpack together.

Q2. You ask if the non-hazardous material must be considered when determining the applicability of the placarding exception in § 172.504(c).

A2. The answer is no.  The weight of non-hazardous material is not included in the determination of aggregate gross weight of the hazardous material for the purposes of the placarding exception for non-bulk packages found in § 172.504(c).

I hope this information is helpful.  Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division



Regulation Sections

Section Subject
172.504 General placarding requirements