USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #20-0019

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

Interpretation Response Details

Response Publish Date:

Company Name: National Motor Freight Traffic Association, Inc.

Individual Name: Lisa O'Donnell

Location State: VA Country: US

View the Interpretation Document

Response text:

April 7, 2020

Lisa O'Donnell
National Motor Freight Traffic Association, Inc
1001 North Fairfax Street, Suite 600
Alexandria, VA  22314

Reference No. 20-0019

Dear Ms. O'Donnell:

This letter is in response to your March 3, 2020, email and phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the non-bulk package aggregate gross weight placarding exception. Specifically, you describe a scenario in which non-bulk packages, such as drums, containing a hazardous material listed on Table 2 of § 172.504(e) are strapped to a pallet. You state that the gross weight of the hazardous material and non-bulk packages is under 1,001 lbs.; however, when the pallet and straps are considered in the shipment, the weight exceeds 1,001 lbs. You ask whether the weight of the pallet must be considered when determining the applicability of the 454 kg (1,001 lbs.) aggregate gross weight placarding exception in § 172.504(c) for non-bulk packages.

The answer is no. The § 172.504(c) exception is based on the gross weight of the packaging and the hazardous materials being transported. Section 171.8 defines gross weight as "the weight of a packaging plus the weight of its contents." Packaging means a receptacle and any other components or materials necessary for the receptacle to perform its containment function. In the scenario you described, the packaging is the non-bulk packaging. Thus, the pallet and straps are part of an overpack used for convenience in handling the packages or consolidating the packages together, they are not part of the packaging. Therefore, the weight of the overpack should not be considered when calculating the gross weight to determine whether it equals or exceeds the threshold amount of 454 kg (1,001 lbs.).

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


Shane Kelley
Director, Standards and Rulemaking Division
Office of Hazardous Materials Safety

171.8, 172.504(c), 172.504(e)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.504 General placarding requirements