# International Association of Fire Chiefs — Hazardous Materials Safety Interpretation

- **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:** Not available
- **summary:** 04-0132 response to International Association of Fire Chiefs concerning 172.500, 172.800.
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- **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>>>

of Transportation
U.S. Department
400 Seventh St., S.W.
Washington, D.C. 20590
Research and
Special Programs
Administration
JUN
15 2004
Chief Ernest Mitchell
President
Ref. No. 04-0132
International Association of Fire Chiefs
4025 Fair Ridge Drive
Fairfax, VA 22033-2868
Dear Chief Mitchell:
This responds to your May 7, 2004 letter addressed to the Honorable Thomas J. Ridge,
Secretary, U.S. Department of Homeland Security (DHS), with a copy to the Secretary
of Transportation Norman Y. Mineta, expressing your strong support for maintaining the
use of the current hazard warning placards for shipments of hazardous materials until a
replacement system has been demonstrated to be effective and the fire service has been
trained in its use. Your letter was referred to me for response.
As you know, in response to concerns that placards could be used by terrorists or
criminals to identify potential targets, the Research and Special Programs Administration
transportation safety and security. The study took into account the views of all
(RSPA) on January 15, 2003, completed a study of the role placards play for
stakeholders, including IAFC, through working group meetings. The study concluded
that the existing placarding system should be retained, but that we should continue to
review the use of alternatives to placards in specific high-risk situations, as well as for
broad application. In considering potential changes to the placarding requirements as
impact on costs, training and international trade that could result from changes in the
part of its continuing review, the study further concluded that we should consider the
current placarding requirements. (The study can be found on our website at
http://hazmat.dot.gov/pubtrain/003RcdactedPlacardingReportSSI.pdf.)
In addition, the DHS is conducting a study to examine alternative methods for
communicating the hazards of hazardous materials transported in rail tank cars. The
study will identify 10 alternatives to placarding for communicating hazards and will
include operational testing of the alternatives identified. The evaluation of the
alternatives will include: (1) technical considerations, such as the speed and accuracy of
the systems and the interoperability of the systems with those currently in use by the
emergency response community; (2) international transportation issues, such as the
impact on international rail transportation between the United States and Canada and
Mexico; (3) the costs associated with the alternatives, including installation, start-up, and
consideration of small urban and rural volunteer first responders; and (4) the speed with
system maintenance costs, as well as cost of training the users, showing particular
040132
$112.500
172.800

<<<PAGE 2>>>

which the alternatives can be implemented, including the time required to train first
responders to use the new technology. DHS expects to complete the study by the end of
2004.
Effective hazard cornmunication is critical to the ability of emergency response personnel
to handle transportation accidents involving hazardous materials. Let me assure you that
consideration of all the potential impacts, especially the potential impacts on emergency
DOT will propose no change to the current placarding system without careful
response and those responsible for planning for and responding to hazardous materials
transportation accidents.
Thank you for your letter. Please feel free to contact me if you have questions or need
additional information.
Sincerely,
This lyles
Frits Wybenga
Deputy Associate Administrator
Office of Hazardous Materials Safety

<<<PAGE 3>>>

May-07-2004 15:51
From-INTL ASSN OF FIRE CHIEFS
+7032739363
T-330 P.002/002 F-269
International Association of Fire Chiefs
4025 Fair Ridge Drive • Fairfax, VA 22033-2868
Telephone: (703) 273-0911
Fax:
(703) 273-9363
7 May 2004
Internet:
www.iafc.org
Honorable Thomas J. Ridge
Boothe
Secretary, U.S. Department of Homeland Security
$172.500
Washington, DC 20528
U.S. Department of Homeland Security
Via facsimile: 2022828401 72.800
Dear Secretary Ridge,
Sacrity Placardin
Over the last year, the International Association of Fire Chiefs (IAFC) has heard persistent rumors that
04-0/34
the Department of Homeland Security (DHS) intends to remove hazardous materials placards from rail
cars for security reasons. In our business, we understand that often, where there's smoke, there's fire. The
AFC supports the current placarding system and works closely with the Research and Special Programs
Administration (RSPA) of the Department of Transportation to administer that system. While we
appreciate the security risks associated with hazardous materials transportation, we oppose the
effective and the fire service has been fully trained in its use.
termination of the current placarding system until a replacement system has been demonstrated to be
There are nearly one million shipments of hazardous materials each day in the United States. While the
overwhelming majority of these shipments reach their destination safely, some spill or catch fire. It is
imperative that emergency responders be able to quickly and accurately identify these materials in order
to safely clean up the hazard and protect thernselves, local citizens, nearby property, and the environment.
trained on handling hazardous materials incidents with the Norsh American Emergency Response Guide
This is an everyday safety issue for America's fire service. For nearly two decades the fire service has
(ERG) which depends on placards for identification of the substances involved. Firefighters and other
emergency responders do not have universal access to sophisticated electronic and software programs to
identify hazardous materials. Most fire departments, especially small and rural departments which are
mostly volunteer, still rely on visual placards for their own safety and the protection of the citizenry.
current placard system is completely ingrained in our response mechanism. Withour it, first responders
Secretary Ridge, public safety rests on the actions and knowledge of emergency first responders. The
request a response to this letter so the IAFC can inform America's fire service of the exact status of this
and the public we are sworn to protect will be endangered. Because of the importance of this issue, I
crucial issue. This is not an issue that can be appropriately decided by administrative fiat.
Please call me if you require additional information on this extremely important issue. I look forward to
hearing from you.
Very truly yours,
Bathrobed?
Chief Emest Mitchell
President
/mws
cc:
Norman Y. Minera, Secretary of Transportation
Providing lealership jar che fire and emergency services since (873
Member; International echnical Committee for the Prevention and Exinction of Fire/Curité Technique International De Prevertion E‹ D'Exinction Du Feu (CTIF)
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