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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 #18-0146

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

Interpretation Response Details

Response Publish Date:

Company Name: Texas Highway Patrol

Individual Name: Brad Gibson

Location State: TX Country: US

View the Interpretation Document

Response text:

May 24, 2019

Brad Gibson
Texas Highway Patrol
6200 Guadalupe Street,
Building P
Austin, TX  78752

Reference No. 18-0146

Dear Sergeant Gibson:

This letter is in response to your November 13, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding.  In your email, you describe a scenario in which a motor vehicle was placarded to indicate a Class 8 corrosive material, but upon inspection of the vehicle, you found that it was transporting packages classed as Other Regulated Material (ORM-D).  However, the hazardous material in question was a Class 8 corrosive material prior to being reclassified as ORM-D.  Specifically, you ask whether this scenario is acceptable within the HMR.
The answer is yes.  Section 172.502(c) states that placards may be displayed for a hazardous material, even when not required, if the placarding otherwise conforms to the requirements of this Subpart F - Placarding.  Additionally, § 172.502(a)(1) states that placarding is permitted when the material being offered or transported is a hazardous material, the placard represents a hazard of the hazard material being offered or transported, and any placarding conforms to the requirements of Subpart F.  While the material in question may have been reclassified as an ORM-D, the material still presents a Class 8 (corrosive) hazard and therefore a Class 8 placard is acceptable. 

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


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

172.502(c), 172.502(a)(1)


Regulation Sections

Section Subject
172.502 Prohibited and permissive placarding