Mr. Bob Thompson — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Admint fratioams FEB 17 2005 Mr. Bob Thompson 4200 Cairo Road | United Propane Gas Companies, Inc. Ref No.: 05-0012 Paducah, Kentucky 42002-2450 Dear Mr. Thompson: This responds to your January 18, 2005 letter and subsequent telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the proper shipping name must be marked on the outside of a cargo tank in addition to the required placards and identification number markings for ammonia anhydrous and propane. The answer is yes. A cargo tank containing a Class 2 material must be marked in accordance with Part 172, Subpart D and placarded in accordance with Part 172, Subpart F. A cargo tank containing a Class 2 material must be marked with the proper shipping name specified in the Hazardous Materials Table (HMT; § 172.101), or an appropriate common name for the material (e.g., "Refrigerant Gas") in accordance with § 172.328. However, § 172.328 provides an exception from the requirement to mark the proper shipping name or common name on certain nurse tanks that are marked in accordance with § 173.315(m). I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, / Chief, Standards Development Office of Hazardous Materials Standards 172.328 172.334 172.519 050012#

Page 2kicheblaub $172,334 $172.519 Placarding 05-0012 QUESTiONS ABOUT PLACARDiNA FOR PROPANE AND ANHydROUS AmMONIA FOR PROPANE iS iT ALRiGHT To hAVE jusT N.N. 1075+ FLAMMABLE GAs oN ALL 4sidES 4.N.1075) FLAMMABLE GAS FoA ANHyOROuS AmmOniA iS iT ALAigHT To HAVE jUST N.N. 1005. NON-FLAMMABLE GAS ALL HSiDES AND INHALATION HAZARA ON BOTH SIDES. /u.N.1005) NON-FLAMMABLE GAS INHALATION HAZARD FRom: BoB Thompson PHonE: 270-442-5557 EXT 25 FAx: 270-444-6380#