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Interpretation Response #99-0307 ([Michels Pipeline Construction, Inc.] [Mr. Rod Day])

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

Interpretation Response Details

Response Publish Date:

Company Name: Michels Pipeline Construction, Inc.

Individual Name: Mr. Rod Day

Location State: WI Country: US

View the Interpretation Document

Response text:

December 10, 1999


Mr. Rod Day                         Ref. No: 99-0307
Michels Pipeline Construction, Inc.
817 W. Main
Brownsville, WI 53006-0128

Dear Mr. Day:

This is in response to your letter Of November 15, 1999, and subsequent telephone conversation with Diane LaValle, of my staff, requesting clarification on placarding requirements under the Hazardous Materials Regulations.  You provided a scenario where you transport permanently secured non-bulk tanks under the provisions of § 173.8 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You ask whether placarding is required when transporting one 35 gallon and one 85 gallon tank in this manner if the aggregate gross weight of both tanks is less than 1001 pounds..

The answer is no.  An exception is provided in § 172.504(c) where a transport vehicle carrying less than 1001 pounds aggregate gross weight (packaging plus contents) of Table 2 hazardous materials in non-bulk packaging need not be placarded.

I hope this information is helpful.



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


Regulation Sections

Section Subject
172.504 General placarding requirements