Gulf States Intermodal — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration DEC 12 2002 Mr. Ned Williams General Manager 7300 North Peters Street Gulf States Intermodal Ret. No. 02-0175 Arabi, Louisiana 70032 Dear Mr. Williams: This responds to your letter regarding whether it is permissible to use foreign language text on placards displayed on portable tanks (approximately 6,000 gallons capacity) imported or exported to, or from: the United States by:water in accordance with the International. Maritime Dangerous Goods (IMDG) Code: I apologize for the delay in responding and hope it has not caused any inconvenience. Text indicating a hazard on a placard, other than the RADIOACTIVE, DANGEROUS, or OXYGEN placards, is not required. When hazardous materials aie offered for transportation or transported under. the provisions of § 171.12; import/export shipments by water, a placard conforming to the specifications in the IMDG Code may be used in place of a corresponding placard which conforms to the placarding requirements of the HIMR, except thạt a bulk packaging; transport vehicle, or freight container containing a material poisonous by inhalation must be placarded. in accordance with subpart F of part 172 of the HMR. Placards conforming to specifications in the IMDG Code may contain foreign language inscriptions or text indicating a hazard (e.g., text displayed in French, Japanese, etc., words). (See §§ 171.12 and 172.519). I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Delus 16-160 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 171.12= 020175 172.519#

Page 2JUN-18-2002 TOE 01:59 PM FAX NO. P. 01/02 Engrum 6-18-2002 § 172.502 Edward I. Mazullo Director, Office of Haz - Mat Standards Placarding BOASSO 400 7" St., S.W U.S. D.O.T. / R.I.S.P.A. (DHM10) A ME R 02-0 175 Washington, D.C. 20590 Rc: Foreign language wording on hazardous materials placards Dear Mr. Mazullo, Gulf States Intermodal (DOT 311230) Division of Boasso America is a transporter of tank containers. Tank containers are considered portable tanks. They have a capacity of approximatcly 6000 gallons. 97% of the moyements that we make are exports to or imports from foreign countrics. At least a portion of the movement is made by water whether wo pick up or deliver to a railroad or a marine terminal. The import shipments arrive with placards that are correct as to size, color and hazard class, but many of the placards have wording that is in a foreign language. We see them local terminal operator, that this foreign wording is not allowed. The Coast Guard tells in French, Spanish, Japanese, etc. Our local Coast Guard office has told P&O Ports, a P&O that the wording must bc in English and that the terminal or the carrier must change Gulf States Internodal contends that item 172.519 of the Hazardous Matcrials Regulations covers this placarding issue. This paragraph allows that cortain hazardous materials shipments can be transported under rules set forth in the I.M.D.G. We contend that Part 5 of the I.M.D.G. allows for any language in the placard as long as the size, color and hazard class requirements are inct. We agrec that the tank, in these circumstances, must also have an orange panel with the U.N. number on both sides, the back and the front. The proper shipping name must be stenciled on both sides in 2" 1 am requesting an opinion, in writing, from your office regarding this matter. Should you agree with our interpretation, then we can stop the unnecessary replacarding of tanks at the New Orleans port facilities. 7300 North Meiers Street Bo asso America Corporation Arabi, LA 70032 Tax: (50-1)277-0113 Tel: (504)279 8.541 www.hoassoamcrlca.com#

Page 3JUN-18-2002 TUE 01:59 PM FAX NO. P. 02/02 A portion of these tanks are unloaded and returned, with residue, back to the wharf for the original placarding can remain on the tank or if the placarding has to be changed to no subsequent shipment back to the original point of loading. We would also like to know if wording or to English for the return movement? We eagerly await your reply. Respectfully, Ned Willians Gencral Manager Gulf States Intermodal 7300 N. Peters Arabi, La. 70032#