{"operation":"document","citation":"01-0049","title":"Naval Magazine — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-04-16","effective_on":null,"summary":"01-0049 response to Naval Magazine concerning 172.510.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0049.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0049.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0049","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010049.pdf","body":"<<<PAGE 1>>>\n\n•\n=\nU.S. Department\nof Transportation\nVashington, D.C. 2059\n00 Seventh Street, S.W\nResearch and\nSpecial Programs\nAdministration\nAPR 16 2001\nMs. Debra Olson\nTransportation Officer\nRef. No. 01-0049\nNaval Magazine\nIndian Island\nBuilding 800\n100 Indian Island Road\nPort Hadlock,\nWA\n98339-9723\nDear Ms. Olson:\nThis is in response to your letter dated February 9, 2001,\nDivision 1.1 and 1.2 materials transported by rail.\nrequesting Clarification of the placarding requirements for\nSpecifically, you ask if it is necessary to placard the rail car\n. with EXPLOSIVE placards on a white square background in addition\ncontainers for transport by vessel and highway.\nto the EXPLOSIVE placards already displayed on the bulk\nSection 172.510 requires that the specified placard for certain\nexplosives be placed on a white square background (See\n§ 172.527). If the placards affixed to the shipping containers\nare not displayed on a white square background the rail cax must\nbe placarded as specified in § 172.510.\npermissible to use the white\nHowever, it is\ntransportation.\nsquare background for all modes of\nTherefore, if the shipping containers are\ninitially placarded with the EXPLOSIVE placards on the white\nsquare\nbackground, no additional placarding is necessary.\nI hope this satisfies your request.\nSincerely,\nTransportation Regulations Specialist\nOffice of Hazardous Materials\nStandards\n\n<<<PAGE 2>>>\n\n_narun\n11724510\n-\nplacardino\nDate: 09 Feb 01\nfor Rait\nFrom: Debra Olson, Traffic Manager, Naval Magazine Indian Island Port Hadlock, WA 98339\nDepartment of Transportation, Ed Maezullo Interpretations Department\n08-0049\nSubj: INTERPRETATION OF THE 49 CODE OF FEDERAL REGULATIONS (CRF), SECTION\n172.510, SPECIAL PLACARDING PROVISIONS: RAIL\n1.\nNaval Magazine Indian Island has within the past several years started shipping 1.1 and 1.2 explosives\nby rail. We have had some interpretation difficulties when it comes to the white square background\nthat is indicative of rail shipments.\n2. We receive International Standard Organization (ISO) containers by vessel to our seaport here at Naval\nare stuffed from military installations overseas and when the reach our port, since we do not have a rail\nMagazine Indian Island. These are the standard 8' X 20' X 8' containers. These shipping containers\nfacility on station, are trucked forty five miles south to Naval Submarine Base Bangor where the rail\nhead is located. The problem is that when these overseas installations stuff the material, they placard\nthe material for vessel and for trucks, not for rail. Therefore, no white square background is placed\ninterpreting the 49 CFR to read that because it is going by rail, we must place additional placards on\nbehind the orange 1.1 and 1.2 placards. Here is where the interpretation gets fuzzy. We, at Traffic, are\nthe rail to reflect the rail placarding requirement.\n(White square background with the orange 1.1 or 1.2, whatever is applicable) on each end and on both\n• We do this by affixing four additional placards\nsides of each railcar. Some of the rail cars, if there are four containers to a railcar, display a total of\ntwenty placards (four on each container and four on the rail car). Our headquarters is interpreting this\nsection differently. Headquarters feels that since the containers themselves are placarded this\nsomehow releases them from the obligation of the white square background placard.\n3. Please clarify this point and tell me if we are doing some additional step by applying the white square\nbackground needlessly. If it is a requirement that is not needed, there would be a considerable cost\nsavings in both time and money by deleting this additional placarding to the railcars. We are expecting\nthe correct interpretation placed in writing for future reference.\nanother rail shipment is the near future and would very much like to have this matter cleared up and\n360 396 5309\n4. Please fax your interpretation to me as soon as possible at (360) 385-7995 or you can send it to us by\nmail at Transportation Officer, Naval Magazine Indian Island, 100 Indian Island Road, Bldg. 800, Port\n5296.\nHadlock, WA 98339-9723. If you have any questions, please feel free to telephone me at (360) 396-\nDetra Qin\nDebra Olson\nTraffic Manager","truncated":false,"body_characters":4254}