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Interpretation Response #20-0025

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

Interpretation Response Details

Response Publish Date:

Company Name: Entergy

Individual Name: Donnie James

Location State: LA Country: US

View the Interpretation Document

Response text:

May 12, 2020

Donnie James
Shipping Technician
Waterford 3 Steam Electric Station
17265 River Road
Kilona, LA 70057

Reference No. 20-0025

Dear Mr. James:

This letter is in response to your March 11, 2020, email and subsequent email conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding visibility. Specifically, you provide the following scenario:

  • Waste Class 7 (radioactive) materials are transported in cargo containers with approximately 1150 cubic ft. capacity each.
  • The radioactive materials are placed directly in the cargo containers with no intermediary packaging.
  • The cargo containers meet the general design requirements of §§ 173.24, 173.24b, and 173.410.
  • You included two pictures of the potential containers and their configuration.

We have paraphrased and answered your questions as follows:

Q1. You ask whether the cargo container meets the § 171.8 definition of a freight container.

A1. The answer is yes. Although the definition of a freight container indicates that its use is "intended primarily for containment of packages (in unit form)," the definition of a bulk packaging means "a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment." Therefore, based on the description and picture of the container, it meets the definition of a freight container. Please note, that the non-specification sift proof bulk packaging will still need to be authorized in accordance with the bulk packaging section assigned in the § 172.101 Hazardous Materials Table.

Q2. You ask whether the cargo container complies with placarding visibility requirements if the container is placarded on all four sides, the placards are clearly visible, and the placards are not obstructed.

A2. The answer is yes. In accordance with § 172.504(a), unless otherwise excepted, each bulk packaging, freight container, unit load device, transport vehicle or rail car must be placarded on each side and each end. Additionally, § 172.516(a) requires that each placard on a motor vehicle must be clearly visible from the direction it faces, except from the direction of another transport vehicle to which the motor vehicle is coupled. This may be met by placards displayed on the freight container loaded on the motor vehicle. Therefore, as described in your email, displaying a placard on all four sides of the freight container meets the general placarding and visibility requirements.

Q3. You describe a scenario where two cargo containers placarded on all four sides with the same placard are placed next to each other lengthwise on a vehicle such that they act as one unit for visibility purposes. In this scenario, the ends of the cargo containers facing each other are not visible. You ask whether cargo containers transported in this configuration would meet the placard visibility requirements without attaching additional placards to the trailer.

A3. The answer is yes, because both freight containers display the same placards. If the freight containers displayed different placards it would not comply with placard visibility requirements (see A2).

Q4. You ask whether § 172.516(a) is limited to freight containers and portable tanks. In your email, you give examples of shrink-wrapped pallets with placards on all four sides or IBCs with placards on all four sides.

A4. The answer is no. Section 172.516(a) lists freight containers or portable tanks as packaging types that may display a placard, instead of the motor vehicle; however, the requirement is that each placard must be readily visible from the direction it faces except when the vehicle is attached to another motor vehicle. Therefore, a placard securely attached or affixed to the IBC or pallet may be used for this visibility requirement, if the placard is visible from the direction it faces. However, the package must be located clear of appurtenances and devices (e.g., ladders, pipes, doors, tarpaulins). Additionally, the placard must represent the hazardous material in the package (see § 171.2(k)).

Lastly, please note that IBCs or other packagings may be substantially smaller than portable tanks and freight containers, which may affect the visibility of a placard when the IBC or package is placed on a flat-bed vehicle.

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

171.2(k), 171.8, 172.101, 172.504(a), 172.516(a), 173.24, 173.24b, 173.410,

Regulation Sections

Section Subject
171.2 General requirements
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table
172.504 General placarding requirements
172.516 Visibility and display of placards