Interpretation Response #22-0050
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Mayo Clinic
Individual Name: Mr. Travis Brandt
Location State: MN Country: US
View the Interpretation Document
Response text:
January 19, 2023
Mr. Travis Brandt, MS, CHMM
Hazardous & Radioactive Waste Management
Mayo Clinic
200 Frist Street SW
Guggenheim 1-12
Rochester, MN 55905
Reference No. 22-0050
Dear Mr. Brandt:
This letter is in response to your May 6, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the placarding of hazardous materials. Specifically, you ask whether your understanding of the placarding requirements is correct for the three scenarios described below.
Scenario 1:
A shipment of hazardous materials in non-bulk packages that contain 2,400 pounds (1,089 kg) of Division 6.2 (Infectious substance) originates from one location. You ask whether your understanding is correct that a placard is not required for this shipment.
Response to Scenario 1:
Your understanding is correct. As provided in Table 2 of § 172.504(e), no placard is required for a material categorized as a Division 6.2 (Infectious substance) material.
Scenario 2:
A shipment of hazardous materials in non-bulk packages originating from one location contains:
- 600 pounds (272 kg) of Division 6.2 (Infectious substance);
- 200 pounds (91 kg) of Class 3 (Flammable liquid); and
- 250 pounds (113 kg) of Class 8 (Corrosive material).
You state that the provision in § 172.504(c) for less than 1,001 pounds (454 kg) of Table 2 material does not apply to this scenario due to the aggregate gross quantity of 1,050 pounds (476 kg) of Table 2 materials. You also state that the DANGEROUS placard may be used in lieu of the CORROSIVE and FLAMMABLE placards. You ask whether your understanding of the placarding requirements applicable to this scenario is correct.
Response to Scenario 2:
You are not required to include the 600 pounds (272 kg) of Division 6.2 (Infectious substance) materials towards the aggregate gross weight of hazardous materials allowed when determining compliance with the provisions in § 172.504(c) because Division 6.2 materials are not required to be placarded. See § 172.500(b)(1). In addition, a shipment consisting solely of 200 pounds of Class 3 (Flammable liquid) material and 250 pounds of Class 8 (Corrosive) material does not require a placard. See § 172.504(c). However, should you choose to permissively placard your vehicle, due to the presence of more than one category of Table 2 material. you may use the DANGEROUS placard in lieu of either the CORROSIVE or the FLAMMABLE placards. See §§ 172.502(c) and 172.504(b).
Scenario 3:
A shipment of hazardous materials in non-bulk packages originating from two locations includes the following quantities of hazardous materials:
Materials loaded at location "Alpha"
- 1,200 pounds (544 kg) of Division 6.2 (Infectious substance)
- 400 pounds (181 kg) of Class 3 (Flammable liquid)
- 50 pounds (23 kg) of Class 8 (Corrosive material)
Materials loaded at location "Beta"
- 2,400 pounds (1,089 kg) of Division 6.2 (Infectious substance)
- 100 pounds (45 kg) of Class 3 (Flammable liquid)
- 150 pounds (68 kg) of Class 8 (Corrosive material)
You state that the exception in § 172.504(b) for use of the DANGEROUS placard does not apply after location "Beta" materials are loaded, and the exception in § 172.504(c) does not apply in either location due to the presence of the Division 6.2 (Infectious substance) material. You ask whether your understanding of the placarding requirements applicable to this scenario is correct.
Response to Scenario 3:
The total amount of covered Table 2 materials after loading the hazardous materials at location "Alpha" and "Beta" is 700 pounds (317 kg). Therefore, the exception in § 172.504(c) still applies when the transport vehicle departs locations "Alpha" and "Beta." See Response to Scenario 2—i.e., no placards are required including the DANGEROUS placard. However, if you choose to permissively placard your vehicle, due to the presence of more than one category of Table 2 material, you may use the DANGEROUS placard in lieu of either the CORROSIVE or the FLAMMABLE placards. See §§ 172.502(c) and 172.504(b).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.500(b)(1), 172.504(b), 172.502(c), 172.504(e)