AGWORKS, Inc — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration SEP 1 5 2000 Ms. Esmeralda Garcia Ref. No. 00-0195 PO Box 250 AGWORKS, Inc. Preston, IA 52069-0250 Dear Ms. Garcia: This is in response to your letter of July 7, 2000, reguesting clarification on placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the weight of bulk containers loaded be included when determining the total weight of Table 2 on the same transport vehicle with non-bulk containers need to materials on the vehicle under $ 172.504 (c). The answer is no. As provided by § 172.504 (c) except for bulk packages, a transport vehicle carrying less than 454 kg (1,001 pounds) aggregate gross weight (packaging plus contents) of Table 2 hazardous materials need not be placarded. When calculating the 454 kg (1,001 pounds) aggregate gross weight, only the weight of Table 2' hazardous materials in non-bulk packaging needs to be included. I hope this satisfies your request. Sincerely, 18 Cea Transportation Regulations Specialist Office of Hazardous Materials Standards <04 000195 172.5#

Page 2FROM : MARTIN AG PHUNE NU.: 3156550450 AGWORKS INC PROGRAMMED TO GROW AGWORKS BAH Sn2.504 July 7, 2000 00-0195 U.S. Department of Transportation Research and Special Programs Administration Office of Hazardous Materials Standards 400 Seventh Street, S.W. Washington D.C. 20590 As a software developer in the agricultural field specializing in programming DOT shipping and placarding requirements for our customers, we have a question regarding regulation 49CFR 172.504(c)(1). This regulation states that placarding is excepted on "A transport vehicle or freight container which contains less than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by Table 2..." Our question is the following: Does this rule take into consideration the weight of any bulk containers that may be in the transport vehicle when determining the total weight on the vehicle? In our interpretation of the regulation, we are taking into account the weight of the bulk container. Is this correct? Esmeralda Garcia Database Manager AGWORKS, Inc. PO BOX 250 PRESTONIA 52069 TEL: 319-689-5485 FAX: 319-689-5483 www.agworks.nct -#