Regulation

171.25

Regulation summary

Section 171.25 establishes the requirement for the use of the IMDG Code.

Question/dilemma

In this scenario, a shipper inquires if it is acceptable to use an IMDG compliant Class 9 placard with the text “MISCELLANEOUS” on it in the US. The shipper explains they have a multi-modal container loaded with non-bulk packages that is transported internationally via vessel in accordance with the International Maritime Dangerous Goods (IMDG) Code. The container has CLASS 9 placards affixed on to it with the text “MISCELLANEOUS” inserted in the white bottom part of the placard. They want to know if this is an acceptable means of placarding under the HMR.

In this interpretation, PHMSA addresses if it is acceptable to use an IMDG compliant placard when transported in the US.

Interpretation summary

In interpretation Ref. No. 21-0064, PHMSA advises that would be an acceptable means of placarding under the HMR. According to §171.25, a hazardous material may be offered for transportation or transported to, from, or within the United States by vessel, and by motor carrier and rail in accordance with the IMDG Code, as authorized in §171.22, provided all or part of the movement is by vessel. Section 5.3.1.1.2 of the IMDG Code prescribes the requirements for placarding of cargo transport units and bulk containers for CLASS 9 materials corresponding to the label model No. 9 found in section 5.2.

Additionally, section 5.2.2.2.1.5 states that for labels other than class 7, “the insertion of any text (other than the class or division number) in the space below the symbol shall be confined to particulars indicating the nature of the hazard and precautions to be taken in handling.” This provision applies to placards affixed to cargo transport units and bulk containers, and thus a CLASS 9 placard containing the text “MISCELLANEOUS” is authorized.

It's also important to note that the IMDG Code refers to placards as enlarged labels.