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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 #21-0008

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

Interpretation Response Details

Response Publish Date:

Company Name: Railsback HazMat Safety Professionals, LLC

Individual Name: Rex C. Railsback

Location State: KS Country: US

View the Interpretation Document

Response text:

June 22, 2021

Mr. Rex C. Railsback
HazMat Specialist
Railsback HazMat Safety Professionals, LLC
312 Lawrence Ave.
Lawrence, KS  66049

Reference No.  21-0008

Mr. Railsback:

This is in response to your January 28, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Department of Transportation (DOT) Special Permit (SP) 16365. Specifically, you ask whether an Intermediate Bulk Container (IBC) that complies with DOT-SP 16365 and all other applicable requirements of the HMR may be marked and labeled instead of placarded if it is marked in conformance with § 172.301 and labeled in conformance with §§ 172.400(a) and 172.514(c)(4).

The answer is yes. Section 7(c)(6) of DOT-SP 16365 states that each tank must be marked and placarded in accordance with the requirements for IBCs. The HMR requires bulk packages to be placarded on each side and each end in accordance with Subpart F of Part 172. However, § 172.514(c) allows authorized packagings to be placarded on only two opposite sides or, alternatively, labeled instead of placarded in accordance with Subpart E of Part 172. Additionally, § 172.336(d) states that when a bulk packaging is labeled instead of placarded in accordance with § 172.514(c), identification number markings may be displayed on the package in accordance with the marking requirements of § 172.301(a)(1).

Finally, an IBC that is labeled instead of placarded may display the proper shipping name and United Nations (UN) identification number in accordance with the requirements of § 172.302(a)(1) in lieu of the UN number on an orange panel or placard (and white square-on-point). See § 172.514(c)(4).

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

172.301, 172.301(a)(1), 172.302(a)(1), 172.336(d), 172.400(a), 172.514(c), 172.514(c)(4)

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings
172.302 General marking requirements for bulk packagings.
172.336 Identification numbers; special provisions
172.400 General labeling requirements
172.514 Bulk packagings