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Interpretation Response #22-0106

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

Interpretation Response Details

Response Publish Date:

Company Name: Clean Earth

Individual Name: Nicholas Prevosti

Location State: NJ Country: US

View the Interpretation Document

Response text:

December 12, 2022

Nicholas Prevosti
Environmental Health and Safety Manager
Clean Earth
115 Jacobus Avenue
Kearny, NJ  07032

Reference No. 22-0106

Dear Mr. Prevosti:

This letter is in response to your October 6, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to prohibited display of placards. Specifically, you ask whether a flip placard displaying "blank" white panels constitutes prohibited placarding in accordance with § 172.502(a)(2). When turned to the "blank" side, a flip placard maintains the square-on-point design (i.e., shape of a placard) but does not display any hazard communication information.

The answer is no, display of a "blank" white flip placard does not constitute prohibited placarding. Similarly, an empty placard holder frame also does not constitute prohibited placarding.

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


Regulation Sections

Section Subject
172.502 Prohibited and permissive placarding