URS Corporations — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W, Speciai Programs Research and Washington, D.C. 20590 Administration NOV 1 8 2003 Mr. Andrew N. Romach Ref. No. 03-0251 Regulatory Manager 1600 Perimeter Park Drive URS Corporations Morrisville, NC 27560 Dear Mr. Romach: This is in response to your September 24, 2003 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the removal of freight container has been unloaded of hazardous materials. placards. Specifically, you ask if the truck driver is responsible for removing placards after a The HMR do not specify when placards must be applied to or removed from a vehicle. unloaded and no longer contains hazardous materials, the placards must be removed prior to transportation of the empty freight container. I hope this satisfies your inquiry. Sincerely, Khar Goo Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 1712 030251#

Page 2FPOM: URS CORP FAX NO.: 9194611371 10-15-03 03:47P P. 02 URS Foster $172.512 September 24, 2003 Placarding Mr. Ed Mazzullo, Director Research and Special Programs Administration Office of Hazardous Material Standards U.S. Department of Transportation Washington, DC 20590-0001 400 7th Street, SW FAX: (202) 366-3012 Dear Mr. Mazzulio: I am writing to you to request a written regulatory interpretation concerning who is responsible for removing the situation under question, the shipper of the hazardous materials hires a truck driver to transport a placards once hazardous matcrials are delivered to the consignce and unloaded from a freight container. In the hazardous materials from the freight container and take possession of the hazardous materials at that placardable quantity of hazardous materials inside a freight container to our facility; our employees unload time. The freight container remains attached to the truck bed. Once unloaded, the truck leaving our facility is empty. Is it the truck driver's responsibility to ensure that all of the placards formerly indicating that 171.2(0(2) before driving off of our premises? hazardous materials were present inside the freight container are removed in accordance with 49 CFR I would appreciate yuur clarification of this question. -.. Sincerely Regulatory Manager Andrew N. Romach URS Corporation 1600 Perimeter Park Drive URS Corporation Tel: 919.461.1220 Morrisville, NC 27560 Fax: 919.461.1371 Andy romach@urscorp.com#