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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #25-0061

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

Interpretation Response Details

Response Publish Date:

Company Name: Ohio Public Utilities Commission

Individual Name: Tom Forbes

Location State: OH Country: US

View the Interpretation Document

Response text:

June 16, 2026

Tom Forbes
Chief, Motor Carrier Enforcement
Ohio Public Utilities Commission
180 E Broad Street
Columbus, OH  43215

Reference No. 25-0061

Dear Mr. Forbes:

This letter is in response to your May 1, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marine pollutant marking requirements. Specifically, you ask if it is a violation of the HMR to not display a marine pollutant marking on a Commercial Motor Vehicle (CMV) carrying multiple hazardous materials (including a marine pollutant) that bears a placard or label specified in subparts E or F of Part 172 on said CMV?

No. As stated in § 172.322(d)(3), the marine pollutant mark is not required on a bulk packaging, freight container, or transport vehicle that bears a label or placard specified in subparts E or F of Part 172. As you stated in your letter, the CMV is placarded; therefore, the marine pollutant marking is not required.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review & Reinvention Branch
Standards and Rulemaking Division

172.322(d)(3)

Regulation Sections

Section Subject
172.322 Marine pollutants