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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 #98-0422 ([BMD Enterprises, Inc.] [Ms. Marilynn Dunn])

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

Interpretation Response Details

Response Publish Date:

Company Name: BMD Enterprises, Inc.

Individual Name: Ms. Marilynn Dunn

Location State: CA Country: US

View the Interpretation Document

Response text:

MAR 4, 1998

 

Ms. Marilynn Dunn
BMD Enterprises, Inc.
4959 East Dakota
Fresno, California 93727

Dear Ms. Dunn:

This is in response to your letter regarding the placarding requirements for vehicles transporting Chlorine gas under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), in accordance with the requirements adopted under Dockets HM-181, and HM-206. I apologize for the delay in responding and hope it has not caused any inconvenience.

You asked for clarification of the appropriate placarding requirements for vehicles carrying up to fifteen 20-pound cylinders of chlorine gas, and whether your understanding is correct that anyone of the five placarding options are acceptable. You provided the following options:

  1. POISON GAS placard with "poison gas" text across center
  2. POISON GAS placard with "1017" across center
  3. POISON GAS placard with "chlorine" across center, for highway and rail
  4. POISON GAS placard with "inhalation hazard" across center (as adopted in HM-206)
  5. POISON GAS placard with "101711 across the center (as adopted under HM-206)

Option "3" is not acceptable. The other options may be used. The effective date for transitional placarding provisions for materials poisonous by inhalation (e.g., Chlorine) expired. [HM-181; 56 FR 47158; 9/18/91] Therefore, since the CHLORINE placard was obsolete as of October 1, 1992, it may no longer be used. In a subsequent final rule, for highway transportation only, until October 1, 2001, placards which conform to specifications for placards in effect (1) on September 30, 1991, or (2) placards specified in the December 21, 1990 final rule may be used, in place of the placards specified in Subpart F of Part 172, in accordance with the "Placard Substitution Table" (PST) in § 171.14. [HM:-181; 57 FR 45446; 10/1/92] The CHLORINE placard is not shown in the "PSTIt as an option for placarding Chlorine gas.

A final rule was published in the Federal Register which adopted new placards for materials poisonous by inhalation (pIH). Therefore, until October 1, 2001, for PIH materials, by all modes of transportation, placards may be used that conform to specifications for placards (1) in effect on September 30, 1991, (2) specified in the December 21, 1990 final rule, or (3) specified in the July 22, 1997 final rule, in accordance with the lIPST" in § 171.14. [HM-206; 62 FR 1217; 01/08/97 and corrections and responses to petitions for reconsideration, 62 FR 39398; 07/22/97]

You also asked if your understanding is correct that a subsidiary Class "811 (CORROSIVE) placard is not required for chlorine, even though it is classified as having a subsidiary hazard class of 118n under the HMR.

Your understanding is correct. Only the POISON GAS (old or new) placard is required to be displayed.

I hope this information, is helpful. If we can be of further assistance, please contact us.

Sincerely,

 

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

Regulation Sections