Georgia Department of Motor Vehicle Safety — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration MAR 22 2005 Capt. Bruce Bugg Law Enforcement Division Ref. No. 05-0051 Georgia Department of Motor Vehicle Safety P.O. Box 80447 Conyers, GA 30013-8047 Dear Capt. Bugg: This responds to your electronic mail requesting clarification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) of the marking requirements for certain bulk packagings. Specifically, you ask whether a bulk packaging that is dual marked as a DOT specification intermediate bulk container (IBC) and a DOT specification portable tank is required to be marked with the identification number as required in § 172.331 for IBCs, or the proper shipping name, the name of the owner or lessee, and the identification number as required in § 172.326 for portable tanks. An IBC must be marked with the identification number in accordance with § 172.331 and a portable tank must be marked with the proper shipping name, the name of the owner or lessee, and the identification number in accordance with § 172.326. Therefore, to satisfy the marking requirements, the dual-marked bulk packaging must be marked with the proper shipping name, the name of the owner or lessee, and the identification number as specified in § 172.326. Also, the bulk packaging must conform to all applicable specification requirerents and be authorized for the hazardous material being transported. I hope this information is helpful. If you have additional questions, please do not hesitate to contact us. Sincerely, Hathe z Michell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.326 050051 172.33/#

Page 2INFOCNTR <PHMSA> From: To: Sent: Wednesday, March 09, 2005 5:45 PM Bruce Bugg [obbugg@dmvs.ga.gov] MIa ture Subject: INFOCNTR <PHMSA> Request for Clarification 3172.326 Flag Status: Follow Up Flag: Flagged Follow up 172 331. Markings 05-0051 packagings. Some bulk packagings are "dual marked" as both a DOT Specification Portable This e-mail requests a written clarification of the marking requirements for certain bulk T'ank and as an Intermediate Bulk Container (IBC) . Io such packagings have to comply with the marking requirements of 49 CFR $172.326 $172.331 (requiring only the ID irequiring proper shipping name number)? and owner I lessee markings) or the requirements of 49 CFR Special Projects Coordinator Capt. Bruce Bugg Law Enforcement Division Ceorgia Department of Motor Vehicle Safety Fhone: 678.413.8825 30013-8047 e-mail: obbugg@dmvs.ga.gov <mailto:obbugg@dmvs.ga.gov>#