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Identification numbers on flatbeds

Regulation

172.302(a)

Regulation summary

Section 172.302(a) establishes general marking requirements for bulk packaging. Hazardous material in bulk packaging must be marked with the identification number specified for the material.

Question/Dilemma

In this scenario, a 500-gallon IBC containing a Class 8 corrosive liquid is transported on an open-sided flatbed truck. The IBC has the correct UN identification number on orange panels on two opposing sides in accordance with 172.302(a)(2). The identification numbers are viewable from either side of the flatbed.

In this interpretation, PHMSA addresses if identification numbers are required on the front and rear of the vehicle.

Interpretation summary

In interpretation Ref. No. 13-0206, PHMSA advises that additional markings in 172.331(c) do not apply because the identification numbers on the IBC are visible.

  • As indicated in 172.302(a), bulk packages with a capacity of less than 1,000 gallons are required to display identification numbers only on two opposing sides.
  • For bulk packages of 1,000 gallons or more, identification numbers must be displayed on all four sides.