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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 #98-0504 ([Minnesota Department of Transportation] [Mr. Michael Ritchie])

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

Interpretation Response Details

Response Publish Date:

Company Name: Minnesota Department of Transportation

Individual Name: Mr. Michael Ritchie

Location State: MN Country: US

View the Interpretation Document

Response text:

MAR 20, 1998


Mr. Michael Ritchie
Office of Motor Carrier Services
Minnesota Department of Transportation
1110 Centre Pointe Curve
Mendota Heights, MN 55118

Dear Mr. Ritchie:

This is in further reference to your August 7, 1997 letter and my January 16, 1998 response concerning the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180). The response to "Ql" was in error and is corrected. Also, the response to "Q3u is revised for clarity.

Q1. A truck in interstate commerce is carrying 800 pounds of "Chlorine, 2.3, UNIO17", a
poisonous gas with subsidiary hazard Class 8 (corrosive), in non-bulk cylinders with no other hazardous material on board. What placard(s) are required?

A1. The POISON GAS placard is required, as prescribed by § 172.504(e), Table 1.

Q2. A truck in interstate commerce carries 1,500 pounds of "Chlorine, 2.3, UNI017," a
poisonous gas with subsidiary hazard Class 8 (corrosive), in non-bulk cylinders with no other hazardous material on board. What placard(s) are required? Since the load exceeds 454 kg. has the placarding requirement changed because of the subsidiary hazard?

A2. The answer is the same as in AI. The fact that the load exceeds 454 kg does not alter the placarding requirement.

Q3. A truck in interstate commerce, carries in non-bulk packagings, 800 pounds of "Bromine, 8, UN1744, PG I, II a poisonous-by-inhalation Hazard Zone A material that is corrosive and has a subsidiary hazard class of Division 6.1 (poisonous material). What placard(s) are required?

A3. Both CORROSIVE and POISON INHALATION HAZARD placards are required, as prescribed by § 172.504(e) Table 2, and § 172.505(a), respectively. The 454 kg (1,001 pounds) exception in § 172.504(c) does not apply to a material such as bromine, which is required to display a subsidiary POISON INHALATION HAZARD placard in accordance with § 172.505(a).

I hope this Information is helpful. Should you have further questions, please contact us.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

181, 172.504

Regulation Sections

Section Subject
172.504 General placarding requirements