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InstituteInterpretations SpotlightHazmat PlacardingTransportationHazmat SafetyHazmat EdgeHazmat markings, Placards, and LabelsEnglishAnalysisFocus AreaUSA

Placarding non-bulk packages less than 1,001 pounds

Regulation

172.504(c)

Regulation summary

Section 172.504(c) establishes the general placarding requirements for non-bulk packaging weighing less than 1,001 pounds.

Question/Dilemma

In this scenario, a non-bulk package containing a Table 2 hazardous material is strapped to a pallet for transportation. The gross weight of the hazardous material and non-bulk package is under 1,001 pounds, but the weight exceeds 1,001 pounds when the pallet and straps are considered.

In this interpretation, PHMSA addresses if the non-bulk package, pallet, and straps must be considered when determining the placarding applicability of the aggregate gross weight of the shipment.

Interpretation summary

In interpretation Ref. No. 20-0019, PHMSA advises the gross weight is based on the package and the hazardous materials being transported. The pallet and straps are part of an overpack used for convenience in handling the packages or consolidating the packages together.

  • The weight of pallet and straps should not be considered when calculating the gross weight to determine whether it equals or exceeds the threshold amount of 1,001 pounds.
  • Only the weight of the package and the hazardous materials applies to the gross weight.
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Hazmat markings, Placards, and Labels
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InstituteInterpretations SpotlightHazmat PlacardingTransportationHazmat SafetyHazmat EdgeHazmat markings, Placards, and LabelsEnglishAnalysisFocus AreaUSA

Placarding non-bulk packages less than 1,001 pounds

InstituteInterpretations SpotlightHazmat PlacardingTransportationHazmat SafetyHazmat EdgeHazmat markings, Placards, and LabelsEnglishAnalysisFocus AreaUSA

Regulation

172.504(c)

Regulation summary

Section 172.504(c) establishes the general placarding requirements for non-bulk packaging weighing less than 1,001 pounds.

Question/Dilemma

In this scenario, a non-bulk package containing a Table 2 hazardous material is strapped to a pallet for transportation. The gross weight of the hazardous material and non-bulk package is under 1,001 pounds, but the weight exceeds 1,001 pounds when the pallet and straps are considered.

In this interpretation, PHMSA addresses if the non-bulk package, pallet, and straps must be considered when determining the placarding applicability of the aggregate gross weight of the shipment.

Interpretation summary

In interpretation Ref. No. 20-0019, PHMSA advises the gross weight is based on the package and the hazardous materials being transported. The pallet and straps are part of an overpack used for convenience in handling the packages or consolidating the packages together.

  • The weight of pallet and straps should not be considered when calculating the gross weight to determine whether it equals or exceeds the threshold amount of 1,001 pounds.
  • Only the weight of the package and the hazardous materials applies to the gross weight.
Answer
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