Conway Transportation Services — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 peta Program dministration JAN 2 6 2001 Mr. Robert Petrancosta Ref. No. 00-0360 Director Conway Transportation Services Safety and Environmental Compliance 110 Parkland Plaza Ann Arbor, MI 48103 Dear Mr. Petrancosta: This is in response to your December 22, 2000, letter regarding the identification number marking requirements for poisonous by inhalation (PIH) materials as specified in $ 172.313(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)• identification number to mark on a vehicle containing two Specifically, you request guidance on determining which different PIH materials in non-bulk packages in the same hazard zone with identical gross weights. Section 172.313 (c) (3) (i) requires a transport vehicle or freight container containing different PIH materials in non-bulk packages be marked with identification number of the material having the greatest aggregate gross weight. same hazard zone and gross weight, either identification number marking may be used on the transport vehicle or freight container. I hope this satisfies your request. Sincerely, Transportation Regulations Specialists Office of Hazardous Materials Standards 112.313 000360#

Page 2• BAH 8172. 313 ()GXi) CTS COn-WAY TRANSPORTATION SERVICES A CTIF COMANY Marking Director ROBERT G. PENTRACOSTA 00-0360 Sately and Environmental Complance December 22, 2000 Mr. Edward Mazzullo, Director Research & Special Programs Administration Offices of Hazardous Materials Safety U.S. Department of Transportation 400 Seventh Street, SW Washington, DC 20590-0001 MARKING REQUIREMENTS FOR PIH MATERIALS REQUEST FOR WRITTEN INTERPRETATION Dear Mr. Mazzullo: As required under § 172.313(c)(3)(i), a transport vehicle containing different materials poisonous by inhalation in the same hazard zone, shall be marked with the identification number of the material having the greatest aggregate gross weight. My question concerns a transport vehicle that contains two different materials poisonous by inhalation in the same hazard zone that have identical gross weight. Example: A transport vehicle is loaded at one facility with 1,000 kg (2,205 pounds) Dichiorosilane, 2.3, UN 2189. Hazard Zone B, and, 1,000 kg (2.205 pounds) Acetone identification number would be required to be displayed? çyanohydrin, stabilized, 6.1, UN 1541, PG 1, Hazard Zone B. Which material Thank you in advance for responding to this inquiry. Sinceraly, Rosser Peppercosto Robert Petrancosta cjg (734) 768-0203 (734) 2115650 FAX wwk.con-way.com 110 PARKLAND PLAZA ANN ARBOR, MI 48103#