Interpretation Response #17-0119

Interpretation Response Details

August 3, 2018

Mr. Andrei Lazourenko
Atlantic Ro-Ro Carriers, Inc.
95 River Street, 3rd Floor
Hoboken, NJ 07030

Reference No. 17-0119

Dear Mr. Lazourenko:

This letter is in response to your September 28, 2017, October 16, 2017, and October 26, 2017, emails requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of enlarged labels in place of placards. You describe the following scenario:

• Your company transports containers of Class 7 (radioactive) material in conformance with the International Maritime Dangerous Goods (IMDG) Code by vessel from international locations to the United States. Enlarged labels on these containers display the applicable radioactive Category Group, activity level, transport index, etc., of the Class 7 material they contain.
• A trucking company that arranges U.S. Territory inland transport of these containers requires the enlarged labels be replaced with Class 7 placards that comply with § 172.556. This placard image does not include a radioactive Category Group or transport index.

Specifically, you ask if enlarged labels that comply with section 5.3.1.1.5.1 in the IMDG Code may remain on containers of Class 7 material transported by vessel to the United States for eventual transportation within the United States by motor vehicle.

The answer is yes. Section 172.519(f) authorizes the use of placards conforming to the specifications in the IMDG Code in place of a corresponding placard conforming to the requirements in 49 CFR Part 172, Subpart F (except for materials poisonous by inhalation).

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 Branch
Standards and Rulemaking Division

172.556, 172.519(f), 172

Regulation Sections