Placarding of Vehicles Containing Over 1,001 Pounds of Materials
Pipeline and Hazardous Materials Safety Administration · Sep 15, 1999 · Reference No. 99-0169
Interprets: 49 CFR § 172.504
Reggie’s quick take
Someone asked whether a vehicle (not a cargo tank) carrying up to 60 gallons of flammable or combustible liquid in non-specification packaging must be placarded based only on the weight of the material or on the material plus packaging, including hoses and piping. The agency said placarding depends on the total aggregate gross weight, packaging included, under § 172.504(a). Here the packaging is non-bulk and used under an exemption. The exemption does not excuse placarding under Part 172, Subpart F, so the vehicle must be placarded.
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.
This is in response to your letter dated June 23, 1999, concerning the requirements for placarding a vehicle, other than a cargo tank, with up to 60 gallons of flammable and combustible liquid in a non-specification packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether placarding is based solely on the weight of the material, or the material plus the packaging (including the hoses and piping).
As provided by § 172.504 (a), a transport vehicle containing over 1,000 pounds aggregate gross weight (packaging plus contents) of a hazardous material covered by Table 2 must be placarded. In this case, the packaging is considered a non-bulk packaging (capacity of less than 119 gallons) and authorized under the terms of an exemption. The exemption grants no relief from the placarding provisions of Part 172, Subpart F; therefore, your meter provers containing flammable liquid and/or flammable gas must be placarded.
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.