Placarding ORM-D as original hazard class
Pipeline and Hazardous Materials Safety Administration · May 24, 2019 · Reference No. 18-0146
Interprets: 49 CFR § 172.502(a)(1), 49 CFR § 172.502(c)
Reggie’s quick take
A shipper asked whether a motor vehicle may keep a Class 8 corrosive placard when the material inside has been reclassified as ORM-D. PHMSA said yes. Under § 172.502(c), placards may be shown even when not required, as long as they meet Subpart F. Under § 172.502(a)(1), placarding is allowed when the placard shows a real hazard of the material. The agency said the material still poses a Class 8 corrosive hazard, so the Class 8 placard is acceptable.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
May 24, 2019
Reference No. 18-0146
This letter is in response to your November 13, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. In your email, you describe a scenario in which a motor vehicle was placarded to indicate a Class 8 corrosive material, but upon inspection of the vehicle, you found that it was transporting packages classed as Other Regulated Material (ORM-D). However, the hazardous material in question was a Class 8 corrosive material prior to being reclassified as ORM-D. Specifically, you ask whether this scenario is acceptable within the HMR.
The answer is yes. Section 172.502(c) states that placards may be displayed for a hazardous material, even when not required, if the placarding otherwise conforms to the requirements of this Subpart F - Placarding. Additionally, § 172.502(a)(1) states that placarding is permitted when the material being offered or transported is a hazardous material, the placard represents a hazard of the hazard material being offered or transported, and any placarding conforms to the requirements of Subpart F. While the material in question may have been reclassified as an ORM-D, the material still presents a Class 8 (corrosive) hazard and therefore a Class 8 placard is acceptable.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division
172.502(c), 172.502(a)(1)
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.