Interpretation Response #98-0424 ([American Trucking Association] [Mr. Paul M. Bomgardner])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: American Trucking Association
Individual Name: Mr. Paul M. Bomgardner
Location State: BA Country: US
View the Interpretation Document
Response text:
MAR 6, 1998
Mr. Paul M. Bomgardner
Hazardous Materials Specialist
American Trucking Association
2200 Mill Road
Alexandria, VA 22314-4677
Dear Mr. Bomgardner:
This is in response to your letter concerning how to determine eligibility for the placarding exception provided in § 172.504(c). I apologize for the delay in responding and hope it has not caused any inconvenience.
Paragraph (c) of § 172.504 provides a placarding exception for a transport vehicle or freight container containing less than 454 kilograms (1,001 pounds) aggregate gross weight of hazardous materials covered by Table 2 of § 172.504(e). The exception does not apply to Table 2 materials contained in bulk packagings or to Table 2 materials which are required, under the provisions of § 172.505(a), to be placarded with POISON INHALATION HAZARD or POISON GAS placards.
Neither the weight of Table 2 materials contained in bulk packagings nor the weight of Table 2 materials which are required, under the provisions of § 172.505(a), to be placarded with POISON INHALATION HAZARD or POISON .GAS placards are included in determining the aggregate gross weight of hazardous materials covered by Table 2, for purposes of eligibility for the exception. For example, 400 kg of a Class 3 material (which is neither inhalation toxic nor packaged in a bulk package) is eligible for the placarding exception even if transported on the same vehicle with 500 kg of a Class 8 material which is inhalation toxic and subject to § 172.505. In this example, the vehicle would be placarded with CORROSIVE placards (under § 172.504(e)) and POISON INHALATION HAZARD placards (under § 172.505(a)).
I trust this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Edward T. Mazzullo
Director, Office of Hazardous Materials Standards