Commonwealth of Virginia — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Severth Street, S.W. of Transportation Washingion, D.C. 20590 Hazardous Materials Safety pipeline and JUN 1 3 2003 Administration Sergeant David Feather Ref. No. 05-0108 Safety Division, Motor Carrier Safety Commonwealth of Virginia Department of State Police P.O. Box 10900 Fairfax Station, VA 22039-0900 Dear Sergeant Feather: This is in response to your April 25, 2005, letter requesting clarification of the Hazardous same placard must be displayed on each side and each end of a transport vehicle. You. Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the describe a situation in which a vehicle transports 600 Ibs of a Division 2.1 (flammable The vehicle is placarded on two sides with a DANGEROUS placard and on the two ends gas), 600 Ibs of a Division 2.2 (non-flammable compressed gas) and 600 Ibs of oxygen. with a Division 2.1 placard. A freight container, unit load device, transport vehicle, or rail car which contains non- bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of § 172.504(e) may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in table 2. Each side and each end of a freight container, unit load device, transport vehicle or rail car must have identical placards in design and quantity. Thus, for the situation you describe, a carrier may not satisfy the placarding requirements by affixing a DANGEROUS placard on each side and affixing a Division 2.1 placard on each end of a . transport vehicle. I hope this satisfies your request. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 172.504 050108#

Page 2BAIt GIN 172.504. Placarding 05 - 0108 Colonel W. Steven Flaherty Superintendent COMMONWEALTH OF VIRGINIA (804) 674-2000 DEPARTMENT OF STATE POLICE Fairfax Station, Virginia 22039-0900 P. O. Box 10900 April 25, 2005 Mr. John A. Gale Chief, Standards Development Pipeline and Hazardous Materials Office of Hazardous Material Standards 400 Seventh Street, S.W. Safety Administration Washington, D.C. 20590 Dear Mr. Gale: enforcement community corcering this matter. I am respectfully requesting an interpretation concerning placarding. A question has been raised in the The situation involves the use of the "Dangerous" placard. If a vehicle were transporting the combination of the following Table 2 materials: 600 pounds of a 2.1 Material 600 pounds of a 2.2 Material 600 pounds of Oxygen Would the use of a 2.1 placard displayed on the front and rear of a transport vehicle and a dangerous 172.504(D)(3)? placard displayed on two sides of the same transport vehicle be in compliance with 172.504(a) & (b) and $172.504 General placarding requirements, reads as follows: load device, transport vehicle or rail car containing any quantity of a hazardous material must be (a) General. Except as otherwise provided in this subchapter, each bulk packaging, freight container, unit and in accordance with other placarding requirements of this subpart, including the specifications for the placarded on each side and each end with the type of placards specified in Table 1 ard 2 of this section placards named in the tables and described in detail in §172.519 through §172.558. (b) DANGEROUS placard. A. freight container, unit load device, transport vehicle, or rail car which placards specified in Table 2 of paragraph (e) of this section may be placarded with a DANGEROUS contains non-bulk packages with two or more categories of hazardous materials that require different placard instead of the separate placarding specified for each of the materials in Table 2 of paragraph (e) of material is loaded therein at one loading facility on a freight container, unit load device, transport of this section. However, when 1,000 kg (2,205 pounds) aggregate gross weight or more of ore category be applied. vehicle, or rail car, the placard specified in Table 2 of paragraph (e) of this section for that category must#

Page 3Page 2 flammable gas if the transport vehicle also contains flammable gas or oxygen and it is placarded with (f) (3) A NON-FLAMMABLE GAS placard is not required on a transport vehicle which contains non- FLAMMABLE GAS or OXYGEN placards, as required. and each end, whether it would be a 2.1 Flammable Gas, or Dangerous. In reading the regulations, The regulations do not clearly state that the transport vehicle must display the same placard on each side placard for the Table 1 or the Table 2 material; while section 172.504(b) permits the use of the use of the some believe that either placard would be in compliance. Section 172.504(a) requires the specified However, neither section requires that the same placard be displayed on each side and each end. Dangerous placard instead of the specified placarding for each of the materials specified in Table 2. You assistance in this matter would be greatly appreciated. Sincerely, Dawdl Peak David Feather, Sergeant Division, Motor Carrier Safety Virginia Department of State Police Safety#