{"operation":"document","citation":"01-0209","title":"Applied Specialties, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-10-05","effective_on":null,"summary":"01-0209 response to Applied Specialties, Inc. concerning 172.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0209.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0209.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0209","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010209.pdf","body":"<<<PAGE 1>>>\n\nTransportatio\nS. Departmer\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nspecial Programs\ndministratiol\nOCT\n5 2001\nMs. Adrainne B. Scheurman\nRef. No.: 01-0209\nCompliance Manager\nApplied Specialties, Inc.\n33555 Pin Oak Parkway\nAvon Lake, OH 44012\nDear Ms. Scheurman:\nThis is in response to your letter requesting clarification of the placarding requirements\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically,\nyou asked if a cargo tank that previously transported a Class 9 material in domestic\ncommerce and was placarded \"Class 9\" must remain placarded when it is empty, but has not\nbeen cleaned.\nThe answer is no. The requirements in § 172.514(b) that a bulk packaging must remain\nplacarded when it is emptied apply only to required placarding. As provided in § 172.504(f)(9),\nplacards are not required on a bulk packaging containing a Class 9 material in domestic\ntransportation. However, a bulk packaging containing a Class 9 material must be\nmarked on each side and each end with the appropriate identification number.\nI trust this satisfies your inquiry.\nSincerely,\nOffice of Hazardous Materials Standards\n010209\n\n<<<PAGE 2>>>\n\nCorbin\nAPPLIED SPECIALTIES INC.\n172. 504 (F) (a)\nPhone Number 440/933-9442\nFax Number 440/933-9439\nPlacarding\nMr. Edward T. Mazzullo\n01- 0z09\nDirector of the Office of Hazardous Material Standards\nUS DOT\nFlash RSPA (DHM-10)\n400 7* Street SW\nWashington, DC 20590-0001\nAugust 3, 2001\nLetter of Interpretation\nDear Mr. Mazzullo:\nAny assistance or direction in helping us determine the correct placarding requirement for the following\nscenerio would be very much appreciated.\nIs placarding required on an empty but not cleaned cargo tanker in domestic highway travel if it had previously\nheld an Environmentally Hazardous Substance, Class 9? In our particular situation, our product contains a\nshow that our product contains the reportable quantity once 133 gallons is exceeded in one container. When\nchemical listed in Appendix A of the 171.101 table that has a reportable quantity of 100 pounds. Calculations\nthe tanker is filled to more than 133 gallons the tanker is placarded with the Class 9 placard and the proper\nshipping name \"Environmentally Hazardous Substance Liquid, N.O.S., (Soduim Nitrite)\" is used on the\npaperwork.\nThe regulations clearly state that a container must remain placarded even after it is empty if it contained a\nhazardous material. In this case, however, after the delivery is made and before the tanker is washed, purged or\nfilled with another product, the tanker only contains a residue of the original product and does not contain\nenough product to meet the requirements of an \"Environmentally Hazardous Substance\" according to the\nAt this point, should the placards remain on the tanker or should they be removed? In order that we comply\ncorrectly with the regulations, please advise us of your opinion of this situation.\nShould you require any further information or clarification of the question, please do not hesitate to contact me\nat 800-933-9915. Thank you for your assistance in this matter.\nRespectfully,\nAdrainne B. Scheurman\nCompliance Manager\n33555 Pin Oak Parkway\nAvon Lake, Ohio 44012","truncated":false,"body_characters":3219}