Texas Propane Gas Association — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Adminisiration JAN - 7 2004 Ms. Texas Jackie R. Richards 8408 N. IH-35 Propane Gas Association Ref. No. 03-0273 Austin, TX 78753 Dear Ms. Richards: This is in response to your letter dated October 27, 2003 and Specifically, you request clarification on the shipping paper subsequent telephone conversation with a member of my staff. retention requirements under § 172.201(e). Your questions are paraphrased and answered as follows: Q1. Does the shipping paper retention requirement only apply to the initial carrier of the hazardous material? Al. No. Each shipper or carrier who provides or receives a shipping paper is subject to the shipping paper retention requirements. 22. May a carrier meet the shipping paper retention requirements if they use a permanent shipping paper? A2. Yes. single copy of the shipping paper, instead of a copy fo: Section 172.201(e) allows the carrier to retain a of each shipment made. each shipment made, if the carrier also retains a record 23. Would a "deliver ticket" meet the shipping paper under a permanent shipping paper? retention requirement as a record of each shipment made A3. Yes, if each "deliver ticket" includes the following information: shipping name, identification number, quantity transported, and date of shipment. 172.201 030273 /3.48 CASTE#

Page 204. retention requirement if they deliver the same hazardous How would a propane dealer meet the shipping paper material without change, but do not file a permanent shipping paper? A4. The propane dealer must retain a copy of each shipping paper, or an electronic image thereof. I hope this satisfies your request. Sincerely, office of Hazardous Materials Standards Transportation Regulations Specialist#

Page 3OCT-27-2003 MON 10:56 AM FAX NO. P. 02 PO. Box 140734(78714) 512-836-8620 8408 N. IH-35 (78753) TPGR Texas Propane ® 800-325-7427 Austin, Texas Gas Association Fax: 512-834-0758 October 27, 2003 BAH 8172.201 (e) Office of Hazardous Material Standards Attr: Deborah Boothe Shipping Papers Research and Special Programs Administration U.S. Department of Transportation 03 - 0273 400 / Street SW Washington, DC 20590 Dear Ms. Bootbe, Per our conversation, I am seeking clarification on the Preparation and Retention of Shipping Papers 172.201 (e). In most circumstances, in the propane industry, we have a propane supplier shat transports the ray and deliver to residences and busine 5e, the date pil and autie stops dinoughout initiad carrier and subject to the same compliance as the propane supplier? shij. nents of a single hazardous material (i.e. one having the same shipping name and 172.201 (e) states A motor carrier that uses a shipping paper without change of multiple idertification numher) may retain a shipping paper, insread of a copy for each shipment made, i the carrier also rerains a record of each shipment made, to include shipping name, identification to retain a copy of each deliver ticket? If so, would the shipping name( liquefied petroleum gas) number, quantity transported, and dare of shipment. So in this case, would a propane dealer have and identification number (1075) have to appear every single deliver ticker? Whet would a propane dealer do in a situation where he delivers the same hazardous material witt: out change, but does nor file a permanent shipping paper? What would the propane dealer have: to do to be in compliance with the ruling? Please explain in detail. I aporeciate your time. Please fax back clarification to (512) 834-0758. Sins erely, Texas Propane Gas Association Jackie R. Richards 8408 N IH 35 Austin, IX 78753 www.txpropane.com#