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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: 12-12-2022
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