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Interpretation Response #99-0205 ([R & L Transfer, Inc.] [Mr. Randy Russell])

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

Interpretation Response Details

Response Publish Date:

Company Name: R & L Transfer, Inc.

Individual Name: Mr. Randy Russell

Location State: OH Country: US

View the Interpretation Document

Response text:

September 8, 1999

 

Mr. Randy Russell                       Ref. No. 99-0205
Director of Safety
R & L Transfer, Inc.
600 Gillam Road
Wilmington, OH 45177

Dear Mr. Russell:

This is in response to your letter dated July 27, 1999, regarding permissive placarding under § 172.502 (c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether it is permissible to display a COMBUSTIBLE placard with the identification (ID) number 1993, a CORROSIVE placard and a DANGEROUS placard on a transport vehicle containing 10,400 pounds of non-bulk packagings containing combustible liquids and 90 pounds of a Class 8 material in non-bulk packagings.

The answer is yes.  A COMBUSTIBLE placard is not required for combustible liquids in non-bulk packagings (§ 172.500 (b)(6)). However, a placard may be displayed for a hazardous material, even when not required, provided the placarding is carried out in conformance with Part 172, Subpart F. A shipper that offers a non-bulk shipment of a hazardous material that does not require display of the ID number may still provide a placard with the ID number displayed thereon, as long as the ID number is representative of the material being shipped.

I hope this satisfies your inquiry.

Sincerely,

 

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

172.301 (a), 172.502, 172.504

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings
172.502 Prohibited and permissive placarding
172.504 General placarding requirements