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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.



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