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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 #21-0042

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 Department of Public Safety

Individual Name: Kelly F. McClatchy

Location State: TX Country: US

View the Interpretation Document

Response text:

June 24, 2021

Sgt. Kelly F. McClatchy
Texas Department of Public Safety
2405 S Loop 250 W
Midland, TX  79703

Reference No. 21-0042

Dear Sgt. McClatchy:

This letter is in response to your April 19, 2021, email and subsequent phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to display of hazard communication (e.g., marks, labels, and placards) on an intermediate bulk container (IBC) transported by highway on a flatbed trailer. Specifically, you provide the following scenario of a transport vehicle carrying IBCs and ask whether it complies with the HMR:

  • Multiple IBCs are transported on a flatbed trailer;
  • The IBCs are marked and labeled, as consistent with §§ 172.400(a)(2) and 172.514(c)(4);
  • Straps are used to secure the IBCs to the transport vehicle, which obscure some of the marks and labels displayed on the IBCs; and
  • As discussed in a subsequent phone conversation, the transport vehicle is placarded and displays the UN identification number (UN ID#) of the hazardous material in the IBCs.

The answer is yes. As described in your scenario, the IBCs are appropriately marked and labeled in accordance with the HMR. The IBC marks and labels serve as the hazard communication for the package and do not serve as the hazard communication for the transport vehicle. Instead, the placard and display of the UN ID# serve as the hazard communication for the transport vehicle. Therefore, the IBC marks and labels may be obscured by a securement strap, similar to how they would be obscured when transported within a closed transport 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

172.400(a)(2), 172.514(c)(4)

Regulation Sections

Section Subject
172.400 General labeling requirements
172.514 Bulk packagings