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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 #21-0064

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

Interpretation Response Details

Response Publish Date:

Company Name: Ocean Network Express (North America) Inc.

Individual Name: Lisa Stone

Location State: VA Country: US

View the Interpretation Document

Response text:

September 2, 2021

Ms. Lisa Stone
Ocean Network Express (North America) Inc.
8730 Stony Point Parkway
Suite 400
Richmond, VA  23235

Reference No. 21-0064

Dear Ms. Stone:

This letter is in response to your June 11, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the placarding requirements for international shipments. You describe a scenario where a shipping (freight) container loaded with non-bulk packages is transported internationally via vessel in accordance with the International Maritime Dangerous Goods (IMDG) Code. You ask whether a CLASS 9 placard affixed on the freight container with the text "MISCELLANEOUS" inserted in the white bottom part of the placard—as shown in the photo—is an acceptable means of placarding under the HMR.

The answer is yes. In accordance with § 171.25, a hazardous material may be offered for transportation or transported to, from, or within the United States by vessel, and by motor carrier and rail in accordance with the IMDG Code, as authorized in § 171.22, provided all or part of the movement is by vessel. Section of the IMDG Code prescribes the requirements for placarding of cargo transport units and bulk containers for CLASS 9 materials corresponding to the label model No. 9 found in section 5.2. Additionally, Section states that for labels1 other than class 7, "the insertion of any text (other than the class or division number) in the space below the symbol shall be confined to particulars indicating the nature of the hazard and precautions to be taken in handling."

This provision applies to placards affixed to cargo transport units and bulk containers, and thus a CLASS 9 placard containing the text "MISCELLANEOUS" is authorized.

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

171.25, 171.22

1 Note that the IMDG Code refers to placards as enlarged labels.

Regulation Sections

Section Subject
171.22 Authorization and conditions for the use of international standards and regulations
171.25 Additional requirements for the use of the IMDG Code