PHMSA letter of interpretation

Placarding Requirements

Pipeline and Hazardous Materials Safety Administration · Dec 22, 1995 · Reference No. 95-0141

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 172.504

This is in response to your letter of September 13, 1995, requesting clarification on the placarding provisions of the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) . Specifically, you ask if materials subject to subsidiary placarding under § 172.505 are eligible for use of the DANGEROUS placard and the 1000 pound exception.

Scenario 1:
What are the placarding requirements for a motor vehicle containing 500 pounds of a Class 3 material with a subsidiary poison inhalation hazard and 1100 pounds of a Class 8 material.

FLAMMABLE and POISON placards are required for the Class 3 material and CORROSIVE placards are required for the Class 8 material. Alternatively, you may use DANGEROUS and POISON placards.

Scenario 2:
What are the placarding requirements for a motor vehicle containing 500 pounds of a Division 5.1 materials with a subsidiary Dangerous When Wet hazard, 600 pounds of a Class 8 material and 300 pounds of a Class 3 material.

OXIDIZER and DANGEROUS WHEN WET placards are required for the Division 5.1 material. In addition, because there is more than 1000 pounds gross weight of Table 2 materials on board, CORROSIVE and FLAMMABLE placards are required, or alternatively you may use DANGEROUS and DANGEROUS WHEN WET placards.

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.