Interpretation Response #26-0031
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Washington State Department of Health
Individual Name: Gregorio Rosado
Location State: WA Country: US
View the Interpretation Document
Response text:
June 23, 2026
Mr. Gregorio Rosado
Project Lead, Low-Level Radioactive Waste Program
Washington State Department of Health
Office of Radiation Detection
101 Israel Rd., SE
P.O. Box 47827
Olympia, WA 98504-7827
Reference No. 26-0031
Dear Mr. Rosado:
This is in response to your March 4, 2026 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the placarding of bulk packagings containing Class 7 low specific activity (LSA) material transported under exclusive use. Specifically, you seek clarification on whether the HM-250 final rule superseded previous guidance regarding the placarding of bulk packages.1
1 HM-250 Final Rule, 79 FR 40590 (Jul. 11, 2014) available at:
https://www.federalregister.gov/documents/2014/07/11/2014-15514/hazardous-materials-compatibility-with-the regulations-of-the-international-atomic-energy-agency-rrr
We have paraphrased and answered your questions as follows:
Q1. You ask if § 172.514 requires a bulk package containing an LSA material consigned to exclusive use under § 173.427(b)(4) to be placarded if the transport vehicle is already properly placarded.
A1. Placards on the transport vehicle do not except the bulk package described in your letter from the hazard communication requirements of Part 172, subparts D, E, and F. Under § 172.514(a), each person who offers for transportation a bulk packaging containing a hazardous material must affix the placards specified for the material in accordance with §§ 172.504 and 172.505. Section 172.504(e), Table 1, Footnote 1 requires Class 7 RADIOACTIVE placards for all shipments required by § 173.427 to be operated under exclusive use. In addition, § 173.427(a)(6)(v) specifies that the shipment must be placarded in accordance with Ssubpart F of Part 172. Alternatively, a bulk packaginge other than a portable tank, cargo tank, flexible bulk container, or tank car with a volumetric capacity of less than 18 cubic meters (640 cubic feet) may be placarded on two opposing sides or, alternatively, may be labeled instead of placarded in accordance with Part 172, subpart E. See § 172.514(c).
Q2. You ask if Letter of Interpretation (LOI) Reference Number 10-0032 remains valid after the publication of the HM-250 final rule.? You further ask that iIf not, to please identify the specific regulatory amendment that superseded that interpretation.
A2. Yes. The amendments adopted under the HM-250 final rule clarified the placarding requirements and did not supersede this letter of interpretation. By revising § 173.427(a)(6) to replace the phrase "transport vehicle" with "shipment," PHMSA corrected the misconception that only the vehicle requires placarding. As noted in the preamble to the HM-250 final rule, this change ensures that LSA material shipments meet all applicable Ssubpart F placarding requirements, including those for bulk packaging in § 172.514.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.504: 172.505; 172.514; 173.427