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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 #21-0046

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

Interpretation Response Details

Response Publish Date:

Company Name: Jacam Catalyst, LLC

Individual Name: Jason Ontjes

Location State: KS Country: US

View the Interpretation Document

Response text:

June 24, 2021

Jason Ontjes
DOT/Fleet Manager
Jacam Catalyst, LLC
205 S. Broadway
Sterling, KS  67579

Reference No. 21-0046

Dear Mr. Ontjes:

This letter is in response to your April 27, 2021, email 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
  • 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