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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 #99-0046 ([Mr. Mark R. Maki])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Mark R. Maki

Location State: OH Country: US

View the Interpretation Document

Response text:

JUL 2, 1999


Mr. Mark R. Maki                                   Ref.  No. 99-0046
626 N. Way Street
Barberton, OH 44203

Dear Mr. Maki:

This is in response to your letter dated February 5, 1999, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Q1.      May a vehicle transport hazardous material on private property without displaying placards?

Al.        As specified in § 171.1, the HMR govern the safe transportation of hazardous material in intrastate, interstate, and foreign commerce.  Vehicles containing hazardous materials that are moved on private property are not subject to the HMR (including placarding).

Q2.      May a vehicle which contains no hazardous material display placards when moved on private property?

A2.      Same answer as Al.

Q3.      When must placards be applied to and removed from a motor vehicle?

A3.      The HMR do not specify when placards must be applied to or removed from a motor vehicle.  However, under § 172.506(a) each person offering a motor carrier a hazardous material for transportation shall provide to the motor carrier the required placards for the material being offered prior to or at the same time the material is offered for transportation.  In addition, no motor carrier may transport a hazardous material in a motor vehicle, unless the placards required for the hazardous material are affixed thereto.

You should also be aware that the Occupational Safety and Health Administration (OSHA) of the Department of Labor requires an employer to retain all hazardous materials markings, labels and placards on incoming packages, freight containers, rail freight cars, motor vehicles and transport vehicles containing hazardous materials, until the material is sufficiently removed from the package, container or vehicle to prevent any potential hazard (29 CFR 1910.1201).

I hope this satisfies your request.



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


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions