Guidanceguidance
03-0154
Brenntag Mid-South, Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Research and JUL 29 2003 Special Programs Administration Mr. A.B. Eargood Brenntag Mid-South, Inc. Ref. No. 03-0154 P.O. Box 20 1405 Highway 136 west Henderson, KY 42419-0020 Dear Mr. A.B. Eargood: •This is in response to your June 30, 2003 letter regarding, the marine pollutant marking requirements for bulk packages under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). A bulk package containing a marine pollutant, regardless of the amount, is subject to the requirements for marine pollutants when 171.4). it is offered for transportation or transported by any mode (S Pollutant" mark is required on each bulk packaging that contains When transporting by highway, rail, or air the "Marine a marine pollutant, and each vehicle or freight container that contains a package However, the "Marine Pollutant" mark is not required on a bulk that requires the "Marine Pollutant" mark. placarded in accordance with Subpart E of F of Part 172, except package or transport vehicle that is already properly labeled or when transported by vessel (§ 172.332 (d) (3)). I hope this satisfies your request. Sincerely, / Transportation Regulations Specialist Office of Hazardous Materials Standards 172.332 030154#
Page 206/30/2003 09:45 FAX 270 826 1486 BRENNTAG MID-SOUTH INC 41001/001 BRENNTAG Stinnes Logistics BAM Brenntag M d-South, Inc. 5172-322 FAX Marine Pollutants Markin TO: RESEARCH AND SPECIAL PROGRAMS U.S.DEPT OF TRANSPORTATION FROM: A.B. EARDOOD J5'U15ca DATE: 0E-30-03 PHONE: 270-830-1318 FAX# 202-366-3012 FAX# 270-826-1486 E-MAIL beargood@brenntag-com NUMBER OF PAGES: 1 Clarification of regulation 172.322. having marpol marking on bulk packing - NO MARKING We have been cited by the state of OHIO for not ON TRANSPORT VEHICLE (BOX TRAILER). The cylinders were marked INHALATION HAZARD, CHORINE, Our trailer contained.2 EMPTY TON CHORINE CYLINDERS. UN 1017RQ. The outside of the box trailer was placarded UN 1017, CORRISIVE. EXCEPT FOR TRANSPORTATION BY VESSEL. I believe the MARINE POLLUTANT MARKING IS NOT REQUIRED regulation. Please send me a letter or fax as to clarify this сиь THANK YOU agor 06-30-03 A B EARGOOD ....... 1405 Highway 136 West Brenntag Mill-South, Inc PO 30x 20 Henderson, KY 42419-0020#
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