{"operation":"document","citation":"04-0132","title":"International Association of Fire Chiefs — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-06-15","effective_on":null,"summary":"04-0132 response to International Association of Fire Chiefs concerning 172.500, 172.800.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0132.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0132.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0132","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040132.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nJUN\n15 2004\nChief Ernest Mitchell\nPresident\nRef. No. 04-0132\nInternational Association of Fire Chiefs\n4025 Fair Ridge Drive\nFairfax, VA 22033-2868\nDear Chief Mitchell:\nThis responds to your May 7, 2004 letter addressed to the Honorable Thomas J. Ridge,\nSecretary, U.S. Department of Homeland Security (DHS), with a copy to the Secretary\nof Transportation Norman Y. Mineta, expressing your strong support for maintaining the\nuse of the current hazard warning placards for shipments of hazardous materials until a\nreplacement system has been demonstrated to be effective and the fire service has been\ntrained in its use. Your letter was referred to me for response.\nAs you know, in response to concerns that placards could be used by terrorists or\ncriminals to identify potential targets, the Research and Special Programs Administration\ntransportation safety and security. The study took into account the views of all\n(RSPA) on January 15, 2003, completed a study of the role placards play for\nstakeholders, including IAFC, through working group meetings. The study concluded\nthat the existing placarding system should be retained, but that we should continue to\nreview the use of alternatives to placards in specific high-risk situations, as well as for\nbroad application. In considering potential changes to the placarding requirements as\nimpact on costs, training and international trade that could result from changes in the\npart of its continuing review, the study further concluded that we should consider the\ncurrent placarding requirements. (The study can be found on our website at\nhttp://hazmat.dot.gov/pubtrain/003RcdactedPlacardingReportSSI.pdf.)\nIn addition, the DHS is conducting a study to examine alternative methods for\ncommunicating the hazards of hazardous materials transported in rail tank cars. The\nstudy will identify 10 alternatives to placarding for communicating hazards and will\ninclude operational testing of the alternatives identified. The evaluation of the\nalternatives will include: (1) technical considerations, such as the speed and accuracy of\nthe systems and the interoperability of the systems with those currently in use by the\nemergency response community; (2) international transportation issues, such as the\nimpact on international rail transportation between the United States and Canada and\nMexico; (3) the costs associated with the alternatives, including installation, start-up, and\nconsideration of small urban and rural volunteer first responders; and (4) the speed with\nsystem maintenance costs, as well as cost of training the users, showing particular\n040132\n$112.500\n172.800\n\n<<<PAGE 2>>>\n\nwhich the alternatives can be implemented, including the time required to train first\nresponders to use the new technology. DHS expects to complete the study by the end of\n2004.\nEffective hazard cornmunication is critical to the ability of emergency response personnel\nto handle transportation accidents involving hazardous materials. Let me assure you that\nconsideration of all the potential impacts, especially the potential impacts on emergency\nDOT will propose no change to the current placarding system without careful\nresponse and those responsible for planning for and responding to hazardous materials\ntransportation accidents.\nThank you for your letter. Please feel free to contact me if you have questions or need\nadditional information.\nSincerely,\nThis lyles\nFrits Wybenga\nDeputy Associate Administrator\nOffice of Hazardous Materials Safety\n\n<<<PAGE 3>>>\n\nMay-07-2004 15:51\nFrom-INTL ASSN OF FIRE CHIEFS\n+7032739363\nT-330 P.002/002 F-269\nInternational Association of Fire Chiefs\n4025 Fair Ridge Drive • Fairfax, VA 22033-2868\nTelephone: (703) 273-0911\nFax:\n(703) 273-9363\n7 May 2004\nInternet:\nwww.iafc.org\nHonorable Thomas J. Ridge\nBoothe\nSecretary, U.S. Department of Homeland Security\n$172.500\nWashington, DC 20528\nU.S. Department of Homeland Security\nVia facsimile: 2022828401 72.800\nDear Secretary Ridge,\nSacrity Placardin\nOver the last year, the International Association of Fire Chiefs (IAFC) has heard persistent rumors that\n04-0/34\nthe Department of Homeland Security (DHS) intends to remove hazardous materials placards from rail\ncars for security reasons. In our business, we understand that often, where there's smoke, there's fire. The\nAFC supports the current placarding system and works closely with the Research and Special Programs\nAdministration (RSPA) of the Department of Transportation to administer that system. While we\nappreciate the security risks associated with hazardous materials transportation, we oppose the\neffective and the fire service has been fully trained in its use.\ntermination of the current placarding system until a replacement system has been demonstrated to be\nThere are nearly one million shipments of hazardous materials each day in the United States. While the\noverwhelming majority of these shipments reach their destination safely, some spill or catch fire. It is\nimperative that emergency responders be able to quickly and accurately identify these materials in order\nto safely clean up the hazard and protect thernselves, local citizens, nearby property, and the environment.\ntrained on handling hazardous materials incidents with the Norsh American Emergency Response Guide\nThis is an everyday safety issue for America's fire service. For nearly two decades the fire service has\n(ERG) which depends on placards for identification of the substances involved. Firefighters and other\nemergency responders do not have universal access to sophisticated electronic and software programs to\nidentify hazardous materials. Most fire departments, especially small and rural departments which are\nmostly volunteer, still rely on visual placards for their own safety and the protection of the citizenry.\ncurrent placard system is completely ingrained in our response mechanism. Withour it, first responders\nSecretary Ridge, public safety rests on the actions and knowledge of emergency first responders. The\nrequest a response to this letter so the IAFC can inform America's fire service of the exact status of this\nand the public we are sworn to protect will be endangered. Because of the importance of this issue, I\ncrucial issue. This is not an issue that can be appropriately decided by administrative fiat.\nPlease call me if you require additional information on this extremely important issue. I look forward to\nhearing from you.\nVery truly yours,\nBathrobed?\nChief Emest Mitchell\nPresident\n/mws\ncc:\nNorman Y. Minera, Secretary of Transportation\nProviding lealership jar che fire and emergency services since (873\nMember; International echnical Committee for the Prevention and Exinction of Fire/Curité Technique International De Prevertion E‹ D'Exinction Du Feu (CTIF)","truncated":false,"body_characters":6902}