{"operation":"document","citation":"05-0168","title":"Department of the Army — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-12-13","effective_on":null,"summary":"05-0168 response to Department of the Army concerning 172.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0168.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0168.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0168","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050168.pdf","body":"<<<PAGE 1>>>\n\n.s. Departmer\nf Transportatio\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nDEC 13 2005\nHazardous Materials Safety\nAdministration\nMr. Charles R. Schulz\nReference No.: 05-0168\nHAZMAT Team Leader\nDepartment of the Army\nDefense Ammunition Center\n1 C Tree Road\nMcAlester, OK 74501\nDear Mr. Schulz:\nThis is in response to your July 8, 2005 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding\nrequirements. You present a number of scenarios with your interpretation of placarding\nrequirements. All scenarios are non-bulk shipments. You ask that we comment on the\naccuracy of your interpretation. Your specific scenarios and interpretations, and our\nresponses are as follows:\nScenario #1:\n4,000 kg of Class 3 (Flammable) material, 200 kg of Class 8\n(Corrosive) material, and 200 kg of Class 4.1 (Flammable Solid)\nmaterial are loaded onto one truck. There are no subsidiary\nhazardous classes.\nSchulz interpretation: You suggest that the \"FLAMMABLE\" placard is required.\nPHMSA comment:\n• As specified in § 172.504(c)(1), \"FLAMMABLE,\"\n\"CORROSIVE,\" and \"FLAMMABLE SOLID\" placards are\nrequired because the aggregate gross weight (4,400 kg) of the\nClass 3, Class 8, and Class 4.1 hazardous materials exceeds 454 kg\n\"DANGEROUS\" placard may be substituted for the\n(1,001 lb). However, as provided in § 172.504(b), the\n\"CORROSIVE\" and \"FLAMMABLE SOLID\" placards.\nScenario #2:\n4,000 kg of Class 3 (Flammable) material, 400 kg of Class 8\nnaterial are loaded onto one truck. There are no subsidiar\nCorrosive) material, and 200 kg of Class 4.1 (Flammable Solid\nhazardous classes.\nSchulz interpretation: You suggest that the \"FLAMMABLE\" and \"DANGEROUS\"\nplacards are required.\nHAH HIN\n•\n050168\n\n<<<PAGE 2>>>\n\nPHMSA comment:\nThe \"FLAMMABLE,\" \"CORROSIVE,\" and \"FLAMMABLE\nSOLID\" placards are required because the aggregate gross weight\n(4,600 kg) of the Class 3, Class 8, and Class 4.1 hazardous\nmaterials exceeds 454 kg (1,001 lb). The placarding exceptions\nprovided in § 172.504(c) may not be used because the Class 3\nmaterial exceeds 454 kg (1,001 lb). However, as provided in\n§ 172.504(b), the \"DANGEROUS\" placard may be substituted for\nthe \"CORROSIVE\" and \"FLAMMABLE SOLID\" placards.\nScenario #3:\n175 kg of Class 8 (Corrosive) material with a subsidiary hazard\nClass 3 (Flammable) material, and 25 kg of Class 5.1 (Oxidizer\nlass of Class 6.1 (Poison Inhalation Hazard) Zone B, 300 kg o:\nmaterial are loaded onto one truck. The Class 3 and Class 5.1\nhazardous materials do not have subsidiary hazards.\nSchulz interpretation: You suggest that the \"CORROSIVE\" and \"POISON\nINHALATION HAZARD\" placards are required.\nPHMSA comment:\nThe \"CORROSIVE\" and POISON INHALATION HAZARD\"\npackagings which are required, under the provisions of\nplacards are required. The weight of Table 2 materials in non-bulk\n§ 172.505(a), to be placarded with \"POISON INHALATION\nHAZARD\" or \"POISON GAS\" placards are not included in\novered by Table 2, for purposes of eligibility for the exception it\nletermining the aggregate gross weight of hazardous material:\n\"FLAMMABLE\" and \"OXIDIZER\" placards are not required\n§ 172.504(c). Therefore, as provided in § 172.504(c), the\nbecause the aggregate gross weight of the Class 3 and Class 5.1\nmaterials is less than 454 kg. However, as provided in\n§ 172.504(b), the \"DANGEROUS' placard may be substituted for\nthe \"CORROSIVE\" placard\nScenario #4:\n1,250 kg of Class 3 (Flammable) material with a subsidiary hazard\nlass of Class 6.1 (Poison Inhalation Hazard) Zone B hazardou\nnaterial, 275 kg of Class 2.1 (Flammable Gas) material, and 20\nkg of Class 4.1 (Flammable Solid) material, are loaded onto one\ntruck. The Class 2.1 and Class 4.1 hazardous materials do not\nhave subsidiary hazards.\nSchulz interpretation: You suggest that the \"FLAMMABLE,\" \"POISON INHALATION\nHAZARD,\" and \"DANGEROUS\" placards are required.\nPHMSA comment:\nThe \"FLAMMABLE,\" \"POISON INHALATION HAZARD,\"\n\"FLAMMABLE GAS,\" and \"FLAMMABLE SOLID\" placards\nare required. However, as provided in § 172.504(b), the\n2\n\n<<<PAGE 3>>>\n\n\"DANGEROUS' placard may be substituted for the\n\"FLAMMABLE GAS\" and \"FLAMMABLE SOLID\" placards.\nScenario #5:\n650 kg of Class 8 (Corrosive) material with a subsidiary hazard\nclass of Class 6.1 (Poison Inhalation Hazard) Zone B material, 675\nkg of Class 3 (Flammable) material, and 875 kg of Classs 4.1\n(Flammable Solid) material, are loaded onto one truck. The Class\n3 and Class 4.1 hazardous materials do not have subsidiary\nSchulz interpretation: You suggest that the \"DANGEROUS and \"POISON\nINHALATION HAZARD\" placards are required.\nPHMSA comment:\nThe \"CORROSIVE,\" \"POISON INHALATION HAZARD,\"\n\"FLAMMABLE,\" and \"FLAMMABLE SOLID\" placards are\nrequired. However, as provided in § 172.504(b), the\n\"DANGEROUS' placard may be substituted for the\n\"CORROSIVE,\" \"FLAMMABLE,\" and \"FLAMMABLE SOLID\"\nplacards.\nI trust this satisfies your inquiry.\nSincerely,\nOffice of Hazardous Materials Standards\n\n<<<PAGE 4>>>\n\nFoster\n$172:504\nDEPARTMENT OF THE ARMY\nDEFENSE AMMUNITION CENTER\n1 C TREE ROAD\nPlacarding\nMCALESTER, OK 74501-9053\n85-0168\nSJMAC-AST\n8 July 2005\nMEMORANDUM FOR: Office of Hazardous Materials Safety\nSUBJECT: Interpretation of Placarding Requirements\nReference: 49 Code of Federal Regulations, 1 October 2004.\nRequest interpretation of Section 172.504 of reference in regards the following\nplacarding scenarios. All are non-bulk shipments.\na.\n4000 kg of Class 3 material; along with 200 kg of Class 8 and 200 kg of Class 4.1\nmaterial, are loaded onto one truck. None of these materials have subsidiary\nhazards.\n1.\nRequired placarding: Flammable (Class 3) placards.\nii.\nRationale: The Class 3 material, though it is listed in 172.504(e) Table 2, has\nan aggregate gross weight of 4000 kg and therefore the exceptions listed in\n172.504(b) and 172.504(c) do not apply. The Class 8 and Class 4.1 materials are\nlisted in Table 2 and have an aggregate combined gross weight of 400 kg, which is\nless than 454 kg and therefore 172.504(c) applies. The weight of the Class 3 material\ndoes not have to be taken into account when determining the applicability of\n172.504(c) for the Class 8 and Class 4.1 material because the Class 3 material has\nalready been placarded for.\nb.\n4000 kg of Class 3 material; along with 400 kg of Class 8 and 300 kg of Class 4.1\nmaterial, are loaded onto one truck. None of these materials have subsidiary\nhazards.\ni. Required placarding: Flammable (Class 3) and Dangerous placards..\nii.\nRationale: The Class 3 material, though it is listed in 1.72.504(e) Table 2, has\nan aggregate gross weight of 4000 kg and therefore the exceptions listed in\n172.504(b) and 172.504(c) do not apply. The Class 8 and Class 4.1 materials are\nlisted in Table 2 and have an aggregate combined gross weight of 700 kg, which is\nmore than 454 kg and therefore 172.504(c) does not apply. The Class 8 and Class\n4.1 materials are listed in Table 2 and are each less than 1000 kg and therefore\n172.504(b) applies.\n\n<<<PAGE 5>>>\n\nC.\n175 kg of a Class 8 material which has a subsidiary hazard of Class 6.1 with an\nInhalation Hazard Zone B; along with 300 kg of Class 3 and 25 kg of Class 5.1\nmaterial, are loaded onto one truck. The Class 3 and Class 5.1 materials do not\nhave subsidiary hazards.\ni.\nRequired placarding: Corrosive (Class 8) and Poison Inhalation Hazard (Class\n6.1) placards.\nRationale: The Class 8 material, though it is listed in 172.504(e) Table 2 and\nhas an aggregate gross weight less than 454 kg, is subject to 172.505(a), due to the\npresence of the Poison Inhalation Hazard subsidiary, and therefore 172504(c) does\nnot apply. The Class 3 and Class 5.1 materials are listed in Table 2 and have an\naggregate combined gross weight of 325 kg, which is less than 454 kg and therefore\n172.504(c) applies. The weight of the Class 8 material does not have to be taken into\naccount when determining the applicability of 172.504(c) for the Class 3 and Class\n5.1 materials because the Class 8 material has already been placarded for.\nd.\n1250 kg of a Class 3 material which has a subsidiary hazard of Class 6.1 with an\nInhalation Hazard Zone B; along with 275 kg of Class 2.1 and 200 kg of Class 4.1\nmaterial, are loaded onto one truck. The Class 2.1 and Class 4.1 materials do not\nhave subsidiary hazards.\ni.\nRequired placarding: Flammable (Class 3); Poison Inhalation Hazard (Class\n6.1); and Dangerous placards.\nil.\nRationale: The Class 2.1 and Class 4.1 materials are listed in Table 2 and each\nhas less than an aggregate gross weight of 1000 kg; so therefore 172.504(b) applies.\n172.504(c) does not apply for the Class 2.1 and Class 4.1 materials because they\nhave a combined aggregate gross weight of 475 kg. which is over the 454 kg limit.\nThe Class 3 material, though it is listed in 172.504(e) Table 2, has an aggregate gross\nweight over 1000 kg, and therefore cannot be covered by the Dangerous placard and\nmust be placarded for. In addition 172.505(a) requires its subsidiary to placarded for\nalso.\ne.\n650 kg of a Class 8 material which has a subsidiary hazard of Class 6.1 with an\nInhalation Hazard Zone B; along with 675 kg of Class 3 and 875 kg of Class 4.1\nmaterial, are loaded onto one truck. The Class 3 and Class 4.1 materials do not\nhave subsidiary hazards.\nRequired placarding: Dangerous and Poison Inhalation Hazard (Class 6.1).\nRationale: The Class 8, Class 3, and the Class 4.1 materials are listed in Table\n2 and each have less than an aggregate gross weight of 1000 kg; so therefore\n172.504(b) applies. The Class 8 material also has a subsidiary hazard which is\nrequired to be placarded for by 172.505(a).\n\n<<<PAGE 6>>>\n\nCharles R. Schulz\nHAZMAT Team Leader\nDefense Ammunition Center\nMcAlester, OK 74501\nDSN: 956-8398\nCOM: (918) 420-8398","truncated":false,"body_characters":9746}