Interpretation Response #24-0003
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Dandy Service Corporation
Individual Name: Samantha Dziak
Location State: PA Country: US
View the Interpretation Document
Response text:
October 09, 2024
Samantha Dziak
Safety Manager
Dandy Service Corporation
916 Brush Creek Road
Warrendale, PA 15086
Reference No. 24-0003
Dear Ms. Dziak:
This letter is in response to your January 12, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking and placarding requirements. Specifically, you describe a truckload of 72 drums of "UN3266, Corrosive liquid, basic, inorganic, n.o.s" and 27 drums of "NA1993, Combustible liquid, n.o.s." with a total gross weight of 38,232 lbs. and 3,658.5 lbs., respectively. It is your understanding of the HMR that this truckload should only be placarded with a “CORROSIVE” placard and thus you did not include any display of the identification numbers for the materials onboard. You seek clarification that your understanding is correct.
We have paraphrased and answered your questions as follows:
Q1. You seek confirmation that you are not required to display identification number markings, in accordance with § 172.332 because you are not subject to the transport vehicle identification number marking requirements for large quantities of a single hazardous material in non-bulk packages, as specified in § 172.301(a)(3).
A1. Your understanding is correct. For § 172.301(a)(3) to apply, all conditions must be fulfilled, including that the transport vehicle contain no other material, hazardous or otherwise. Furthermore, generally, transport vehicles containing non-bulk packages of hazardous material are not subject to identification number marking requirements. The exceptions are for large quantities of a single hazardous material in non-bulk packages (§ 172.301(a)(3)) and for certain poisonous by inhalation materials (§ 172.313(c)).
Q2. You seek confirmation that you are not required to display placards or an identification number for a transport vehicle carrying NA1993 material in non-bulk packagings.
A2. As provided in § 173.150(f), a material, such as NA1993, described and classed as a combustible liquid that is transported in a non-bulk packaging is not subject to the HMR, unless the combustible liquid is a hazardous substance, a hazardous waste, or a marine pollutant. You did not provide information as to whether the combustible liquid is a hazardous substance, a hazardous waste, or a marine pollutant; however, based on the copy of the shipping paper provided with your request, indicating the material as non-hazmat, it is the opinion of this Office that your understanding is correct that the transport vehicle is not subject to placarding or identification number marking requirements for the NA1993 material in non-bulk packagings.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.301(a)(3), 172.313(c), 172.332, 173.150(f)