Interpretation Response #24-0123
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: CleanHarbors Environmental Services
Individual Name: James Lynn
Location State: IL Country: US
View the Interpretation Document
Response text:
March 27, 2025
James Lynn
Transportation Compliance Specialist
CleanHarbors Environmental Services
20 Tucker Drive
Caseyville, IL 62232
Reference No. 24-0123
Dear Mr. Lynn:
This letter is in response to your November 20, 2024 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. Specifically, you request clarification regarding the usage of the DANGEROUS placard for bulk and non-bulk packages containing hazardous materials loaded at one location in accordance with § 172.504(b).
Your questions are paraphrased and answered below:
Q1. For a mixed load of bulk and non-bulk packages, you ask whether the gross weight of the bulk package(s) must be considered when determining eligibility of the use of a DANGEROUS placard.
A1. The answer is no. The DANGEROUS placard applies only to non-bulk packages of hazardous materials, in accordance with § 172.504(b).
Q2. If the aggregate gross weight for a particular hazardous material class—including the weight of any bulk package(s)—exceeds 2,205 pounds, you ask whether the vehicle must be placarded for non-bulk packages of that hazard class even though the aggregate gross weight of the non-bulk packages do not meet the 2,205 pounds aggregate gross weight requirement separately.
A2. The answer is no. See answer A1.
Q3. You provided an example of a transport vehicle loaded with a Class 8 bulk package at 2,500 pounds, an aggregate of Class 8 non-bulk packages at 500 pounds, an aggregate of Class 3 non-bulk packages at 500 pounds, and an aggregate of Division 4.1 non-bulk packages at 500 pounds. You ask whether the Class 8 non-bulk packages would be covered by the DANGEROUS placard or would the transport vehicle have to be placarded separately because of the Class 8 bulk package.
A3. The answer is yes. A transport vehicle which contains non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of § 172.504 may be placarded with a DANGEROUS placard instead of the separate placarding specified. As provided in your example, none of the representative hazard classes in non-bulk packages exceed 2,205 pounds in the aggregate including Class 8 non-bulk packages.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards and Development
Standards and Rulemaking Division
172.504, 172.504(b)
Regulation Sections
| Section | Subject |
|---|---|
| 172.504 | General placarding requirements |