Hazardous Materials Division, Federal Motor Carrier Safety Administration — Hazardous Materials Safety Interpretation

Page 1.... Memorandum U.S. Department of Transportation Research and Administration Special Programs Date: MAY 2 1 2002 Reply to Attn. of: Ref. No. 02-0029 Subject: Response to Request for Interpretation • Delmer Billings for finer wher Chief, Standards Development Office of Hazardous Materials Standards To: William Quade Chief of Hazardous Materials Division Federal Motor Carrier Safety Administration This responds to your request for clarification, by memo dated January 25, 2002, related to the marking and placarding requirements applicable to the transportation of propane in storage tanks under the Hazardous Materials Regulations (HMR;49 CFR Parts 171 -1 80). Specifically, you requested our office to review your draft of interpretation and clarify any issues, if applicable. Note, your letter of clarification has been reviewed and revised as follows: Q1. What is the marking requirements for a propane storage tank meeting the definition of a bulk package that is transported by highway in accordance with the provisions of 49 CFR 173.315()? A1. Under the requirements in 49 CFR §172.302 and §172.331, a storage tank that is a bulk packaging must be marked with the identification number. If the tank capacity is greater than 1000 gallons, the tank must be marked on each side and each end. If the tank capacity is less than 1000 gallons, the tank need only be marked on two opposing sides. In addition, § 172.331 requires the transport vehicle to be marked if the identification number is not visible. Q1. What is the placarding requirements for a propane storage tank meeting the definition of a bulk package that is transported by highway in accordance with the provisions of 49 CFR 173.315(j)? Al. Under the requirements in 49 CFR §172.504 and §172.514, a bulk package containing any quantity of HM must be placarded on each side and each end. If the placards are not visible, the transport vehicle must also be placarded. Section 172.514 also permits a bulk storage tank with a#

Page 2. 7 • - volumetric capacity of less than 18 cubic meters (640 cubic feet) to be placarded on two sides, or alternatively, labeled in accordance with subpart E of 49 CFR Part 172. In all cases, however, the transport vehicle must have placards that are visible on all four sides. I trust this satisfies your inquiry. If this Office can be of further assistance, please contact us. ##

Page 3Webb • U.S. Department Memorandum Of Transportation Federal Motor Carrier $|73.315 Safety Administration Midwest Service Center Cargo Fanks Subject: Request for Interpretation Date: 022-9002 00L4 Marking & Placarding Requirements for Propane Storage Tanks From: Joe DeLorenzo HazMat Specialist In Reply Refer To: MC-EFM-SV To: Bill Quade Chief, HazMat Division Attached is a request for interpretation, with a proposed answer regarding the marking and placarding requirements for a propane storage tanks transported in accordance with 49 CFR 173.315(). Also attached are several interpretations that were reviewed in developing this request. In some cases these interpretations conflict with one another or do not provide a comprehensive answer to the general question, and this was the primary reason for developing provided for at the leo han hamn pounds ain, it sars the a cardie eepion basis inv these issues. the regulations for this as these are bulk packages. The attached interpretation would clarify Please feel free to contact me if you need any additional information. correct for ture period ie 1987 cc: Danny Shelton Attachments)#