{"operation":"document","citation":"05-0080","title":"Ms. Amy Dean — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-05-05","effective_on":null,"summary":"05-0080 concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0080.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0080.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0080","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050080.pdf","body":"<<<PAGE 1>>>\n\nJ.S. Department\nof Transportatior\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nAdministration\nHazardous Materials Safety\nMAY 5 2005\nMs. Amy Dean\nRef. No. 05-0080\n1161 Alter Way\nBroomfield, CO 80020\nDear Ms. Dean:\nThis is in response to your April 4, 2005 letter regarding the appropriate shipping\ndescription for various fertilizer blends under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Specifically, you ask about the appropriate shipping\ndescriptions for two fertilizer blends. The first blend consists of 81% ammonium nitrate,\n0-2% talc or conditioning agent, and 19% mono ammonium phosphate. The second\nfertilizer blend consists of 66% ammonium nitrate, 19% mono ammonium phosphate, and\n15% potash.\nSection 173.22 specifies that it is the shipper's responsibility to properly class and\ndescribe a material in accordance with the HMR. This office does not perform that\nfunction. However, based on the information provided, it is our opinion that the first\nfertilizer blend specified should be described as \"Ammoniur nitrate based fertilizer, 5.1,\nUN2067\" and the second fertilizer blend should be described as \"Ammonium nitrate\nbased fertilizer, 9, UN2071.\"\nI hope this information is helpful.\nSincerely,\nHithe 7. Mithell\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n172.101\n050080\n\n<<<PAGE 2>>>\n\nSatterthwaite\n$172.101\nApplicubility\n05'0080\nApril 4, 2005\nBy fax 202-366-3012\nMr. Edward Mazzullo\nU.S. DOT/RSPA (DHM-10)\nDirector, Office of Hazardous Materials Standards\n400 7' Street, S.W.\nWashington, DC 20590-0001\nRe: Letter of Interpretation (172.101 HAZARDOUS MATERIALS TABLE)\nDear Mr. Mazzullo:\nI have a client who blends and then transports (oy truck) a fertilizer blend of 81%\n52- (mo monium irate at) To erent ad on conditioning gent a 099%\n11-52-0 and 15% 0-0-60 (potash). They were told by the DOT that over 1000 pounds of\nmmonium nutrate requires a placard no matter if it is blended with another fertilize\nther transporters (typically fertilizer suppliers) of blended ammonium nitrate indicat\nthey don't placard any of their ammonium nitrate blends but can't provide me with any\nexemptions, etc. of why it is exempt.\nI found a letter of interpretation from the USDOT RSPA (Ref. No. 02-2039) where they\nagree that a b end of 31.25% ammonium nitrate, 20.83% phosphate and 47.91% potash\ndid not require a placard because it should be classified as Class 9, UN2071, III.\nAccording to he special provisions, this entry may only be used for uniform, ammonium\nnitrate-base fertilizer mixtures, containing nitrogen, phosphate or potash, meeting the\nfollowing criteria: (1) Contains not more than 70% ammonium nitrate; and (2) Contains\nnot more than 0.4% total combustible, organic material calculated as carbon or with not\nmore than 45%, ammonium nitrate and unrestricted combustible material. Fertilizers\nwithin these composition limits are only subject to the requirements of this subchapter\nwhen transported by aircraft or vessel, and are not subject to the requirements of this\nsubchapter if shown by a trough test, as specified in the UN Manual of Tests and Criteria,\nPart III, Sub-section 38.2 (IBR, see §171.7 of this subchapter), not to be liable to self-\nsustaining decomposition.\nThe only other appropriate classification for ammonium nitrate based fertilizer appears to\nbe a Class 5.1. The special provision for Class S.1 is as follows: This description may be\n\n<<<PAGE 3>>>\n\nused only for uniform mixtures of fertilizers containing armonium nitrate as the main\ningredient within the following composition limits: a. Not less than 90% ammonium\nnitrate with not more than 0.2% total combustible, organic material calculated as carbon,\nnitrate; or b. Less than 90% but more than 70% ammonium nitrate with other inorganic\nand with added matter, if any, that is inorganic and inert when in contact with ammonium\nmateriais, or more than 80% but less than 90% ammonium nitrate mixed with calcium\ncarbonate and/or dolomite, and not more than 0.4% total combustible, organic material\ncalculated as carbon; or c. Ammonium nitrate-based fertilizers containing mixtures of\nammonium nitrate and ammonium sulphate with more than 45% but less than 70%\naminonium nitrate, and not more than 0.4% total combustible, organic material calculated\nas caroon such that the sum of the percentage of compositions of ammonium nitrate and\nammonium sulphate exceeds 70%.\nIs it basically correct that the special provisions for a Class 9 pertain only to blends with\ness than 70% ammoniun nitrate and blends greater than 70% would have a Class 5.\nlacard? So the 66% blend would fall under Class 9 and the 81% blend would have to b\na Class 5.1?\n•Thank you in advance for your assistance.\nSincerely;\ninner\nDcau\nAmy Dean\n1161 Alter Way\nBroomfield, CO 80020","truncated":false,"body_characters":4849}