Guidanceguidance
04-0102
Brenntag Stinnes Logistics — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research04-0102
Page 1400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration JUN 16 2004 Mr. A. B. Eargood Reference No.: 04-0102 Brenntag Stinnes Logistics P. O. Box 20 Henderson. KY 42420 Dear Mr. Eargood: This is in response to your letter concerning the labeling requirements under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). Specifically, you ask whether the labels required by § 172.406 on DOT 106 or 110 multi-unit tank car tanks may be stenciled on each end of the tank car tank. In a conversation with a member of my light green respectively. You propose to paint the ends of the cylinders white and stencil staff, you stated that the cylinders for the chlorine and sulfur dioxide are painted gray and the labels in the white area. The answer is yes provided the stenciled labels fully conform to all requirements for durability, design, size and color specified in §§ 172.407, 172.416, and 172.442. I trust this satisfies your request. Sincerely, tatter. michel Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 172-4706 040102#
Page 204/19/2004 09:15 FAX 270 826 1486 BRENNTAG MID-SOUTH INC 4002 BRENNTAG Stinnes Logistics Corbin Brenntag Mid-South, Inc. 5172.406 DIRECTOR OF HAZARDOUS MATERIAL STANDARDS EDWARD MAZZULLO Labeling 400 7th STREET SW U.S. DEPARTMENT OF TRANSPORTATION 04 - 0102 WASHINGTON, DC 20590-0001 DEAR MR. MAZZULLO, BRENNTAG MID-SOUTH, INC. TRANSPORTS DOT 106 CYLINDERS CONTAINING CHLORINE UN1017 AND SULFUR DIOXIDE UN1079 WHICH REGUIRE A INHALATION HAZARD AND A CORROSIVE LABEL TO BE DISPLAYED ON EACH END OF THE CYLINDERS. REGULATION 172.406 (e) (3) - WE HAVE FOUND THAT RETAINING LABELS ON EACH END OF THE CYLINDERS BRENNTAG TRANSPORTS THESE CYLINDERS BY FLAT BED TRAILERS. HAS BEEN A PROBLEM. STILL LOOSE TAGS IN TRANSIT. WE HAVE CHANGED TAG MATERIAL, GROMMETS AND WIRE, BUT OF THE CYLINDER INSTEAD OF A TAG? MY QUESTION IS, CAN A STENCIL BE USED ON EACH END WE ARE NOW USING. THE STENCIL WOULD BE THE SAME AS THE TAG (COPY ATTACHED) ELIMINATE THE DRIVER HAVING TO STOP ONTHE SIDE OF THE ROAD TO A PERMANENT TAG ON EACH END OF THE CYLINDERS WOULD REPLACE TAGS THAT HAVE BLOWN OFF. - color of aye. THE COLOR OF THE CHLORINE UN1017 IS GRAY AND THE COLOR OF THE SULFUR DIOXIDE UN1079 IS LIGHT GREEN. TO COMPLY WITH THE CYLINDERS AND THE STENCIL WOULD BE PLACED OVER THE WHITE WITH THE REGULATIONS A WHITE AREA WOULD BE PAINTED ON EACH END OF THE BLACK ROLLED ON FORMING THE LABEL. YOUR RESPONSE. I APPRECIATE YOU LOOKING INTO THIS MATTER AND AWAIT THANK YOU, BRENNTAG MID-SOUTH, INC. PARESCO 1405 HWY 136 WEST HENDERSON, KY 42420 P O BOX 20 A B EARGOOD FAX 270-826-1486 270-830-1318 beargood@brenntag.com Brenntag Mid-South, inc. P.O. BOx 20 1405 Highway 136 West Henderson, KY 42419-0020#
Page 304/19/2004 09:15 FAX 270 826 1486 BRENNTAG MID-SOUTH INC 0003 BRENNTAG MID-SOUTH, INC. INHALATION HAZARD CORROSIVE#
Page 404/19/2004 09:15 FAX 270 826 1486 BRENNTAG MID-SOUTH INC 4001 BRENNTAG Stinnes Logistics Brenntag Mid-South, Inc. FAX TO: EDWARD MAZZULLO FROM: A. B. EARDOOD DATE: 04/19/04 PHONE: 270-830-1318 FAX# 202-366-3012 FAX# 270-826-1486 E-MAIL beargood@brenntag.com NUMBER OF PAGES: 3 LETTER AND TAG ATTACHED 1405 Highway 136 West Brenntag Mid-South, Inc. P.O. Box 20 Henderson, KY 42419-0020#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.