NASA-White Sands Test Facility — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration OCT 28 2005 Mr. Paul Goodwin Ref No.: 05-0189 Transportation Manager NASA-White Sands Test Facility 12600 NASA Road Las Cruces, NM 88012 Dear Mr. Goodwin: This responds to your July 28, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a closed transport vehicle containing ten 650 pound cylinders of methylhydrazine, a Hazard Zone A poisonous by inhalation (PIH) material, must be placarded with the POISON INHALATION HAZARD placard provided in § 172.555. In addition, you ask if the transport vehicle must be marked in accordance with §§ 172.313. As provided in § 172.504(e), a transport vehicle containing any amount of Division 6.1, Hazard Zone A or B material (i.e., methylhydrazine) must display the placards depicted in § 172.555 on each side and each end. In addition, because your transport vehicle contains more than 2,205 pounds of methylhydrazine, it must be marked on each side and each end with "UN 1244" (§ 172.313(c)). The identification number must be displayed on orange panels or placards as specified in § 172.332, or on white square-on-point configurations as prescribed in § 172.336(b). Also note that § 172.313(a) requires the words "Inhalation Hazard" to be marked in association with required labels, placards, and shipping name when appropriate. This requirement applies to the package itself. Therefore, the words "Inhalation Hazard" must e marked in association with the label on non-bulk packagings; bulk packaging such as argo tank or rail tank car must be marked with the words "Inhalation Hazard" ir apear on the lach or placarl, this marking is id re Wiren the words "inhalation Hazard" I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, 172:504 Chief, Standards Nevelopmen laterials Standards 172555 172.333 050189#

Page 2Page 1 of 4 Drakeford, Carolyn <PHMSA> Supko From: Gorsky, Susan <PHMSA> Sent: Thursday, July 28, 2005 9:16 AM §172.504 To: Drakeford, Carolyn <PHMSA> Subject: FW: Placard problem $172.555 Could you put this into the interp system please? Thanks. §112.333' From: Paquet, Ryan <FMCSA> -----Original Message----- Placarding Marting To: Gorsky, Susan <PHMSA> Sent: Thursday, July 28, 2005 7:31 AM Cylinder 85-0189 Subject: FW: Placard problem Susan, could you please have someone look at the following flood of emails and let me know what they make of it? Thank you very much! Ryan -----Original Message-..-- From: Goodwin, Paul [mailto:pgoodwin@smtp3.wstf.nasa.gov] Sent: Wednesday, July 27, 2005 5:53 PM Cc: ###Gary Lindsey (lindseyg@all-pak.com); ####Mike Brennan To: Paquet, Ryan; Lynch, Tom <PHMSA> Subject: FW: Placard problem not to beat a dead horse BUT..I have been going round and round with several people in the aerospace and Lady and Gentlemen, taught and I trust your opinions so here is a scenario: hazmat transportation community for months about a placarding interpretation that differs from what I have been How would you placard Methylhydrazine for a non bulk shipment of 10 cylinders ( 650 Ibs. a piece) in an enclosed van going from one place (Worcester, MA) directly to another place (Trenton, NJ). I checked the DOT exemption to see if there was any relief from placarding regulations and there was not! DOT has already stated his interpretation for another previous shipment of MMH as follows: "Because this material is a 6.1, Hazard Zone A (therefore found in Table 1 of 172.504) the transport vehicle must be placarded when any amount of the material is transported. As placard (see below, the words "Inhalation Hazard must be on the placard). Also, 172.516 (c) shown in Table 1, the placard required is found in 172.555. As you can see, this is a specific (7) states: "Affixed to a background of contrasting color, or must have a dotted or solid line outer border which contrasts with the ba. kground color (My opinion - Silver is not contrasting enough). " Other people in the aerospace and hazmat transportation community, are citing 172.313 and or 172.332 : §172.313 Poisonous hazardous materials. In addition to any other markings required by this 7/28/2005#

Page 3Page 2 of 4 subpart c) A transport vehicle or freight container containing a material poisonous by inhalation in non-bulk packages shall be hazardous material in the § 172.101 Table, subject to the following provisions and limitations: marked, on each side and each end as specified in § 172.332 or § 172.336, with the identification number specified for the 2) The transport vehicle or freight container is loaded at one facility with 1,000 kg (2,205 pounds) or more aggregate gross 1) The material is in Hazard Zone A or B; (3) If the transport vehicle or freight container contains more than one material meeting the provisions of weight of the material in non-bulk packages marked with the same proper shipping name and identification number; and this paragraph (c), it shall be marked with the identification number for one material, determined as follows: (i) For different materials in the same hazard zone, with the identification number of the material having the greatest aggregate gross weight; and (ii) For different materials in both Hazard Zones A and B, with the identification number for the Hazard Zone A material. §172.332 Identification number markings. markings must be displayed on orange panels or placards as specified in this section, or on white square-or-point (a) General. When required by §§ 172.301, 172.302, 172.313, 172.326, 172.328, 172.330, or 172.331, identification number (b) Orange panels. Display of an identification number on an orange panel shall be in conformance with the following: configurations as prescribed in § 172.336(b). border. The identification number shall be displayed in 100 mm (3.9 inches) black Helvetica Medium numerals on the orange (1) The orange panel must be 160 mm (6.3 inches) high by 400 mm (15.7 inches) wide with a 15 mm (0.6 inches) black outer (2) The orange panel may be made of any durable material prescribed for placards in $172.519, and shall be of the orange panel. Measurements may vary from those specified plus or minus 5 mm (0.2 inches). than 18 points high. (3) The name and hazard class of a material may be shown in the upper left border of the orange panel in letters not more (4) Except for size and color, the orange panel and identification numbers shall be as illustrated for Liquefied petroleum gas: 1075 (1) The identification number shall be displayed across the center area of the placard in 88mm (3.5 inches) black Alpine (c) Placards. Display of an identification number on a hazard warning placard shall be in conformance with the following: Gothic or Alternate Gothic No. 3 numerals on a white background 100 mm (3.9 inches) high and approximately 215 mm (8.5 (2) The top of the 100 mm (3.9 inches) high white background shall be approximately 40mm (1.6 inches) above the placard inches) wide and may be outlined with a solid or dotted line border. horizontal center line. (3) An identification number may be displayed only on a placard correspor ding to the primary hazard class of the hazardous (5) The name of the hazardous material and the hazard class may be shown in letters not more than 18 points high (6) If an identification number is placed over the words) on a placard, the word(s) should be substantially covered to mmediately within the upper border of the space on the placard bearing the identification number of the material maximize the effectiveness of the identification number. (d) Except for size and color, the display of an identification number on a placard shall be as illustrated for Acetone: 7/28/2005#

Page 4Page 3 of 4 - 1% 1090 3½ 2% - 3 14 spen• DOT 13 HELP? Are there several ways to placard this shipment ? Should I think about sending this question onto Mr. Mazzullo C US DOT Letters of Interpretation of the HMR? thank you for your expertise and intellect; Sincerely 505-524-5781 Paul Goodwin, Transportation Manager From: Gallegos, Janie (DESC) [mailto:Janie.Gallegos@dla.mil] To: Goodwin, Paul Sent: Tuesday, July 19, 2005 10:37 AM Subject: FW: Placard problem Cc: Mokry, Catherine (DESC) Good Morning Thank you for bringing your concerns to my attention and for providing the photos Paul, they had offered the orange panel but that the carrier they were instrumental with our review of the regulations. stated they had the placards #### informed me that In reviewing rule 49 CFR 172.332(a) it identifies three options to display the point configuration. dentification number markings via orange panel, placards or on white square-on- The carrier opted to use the placard method. Please see 4' CFR 172.332 (c) (6) which also states, (s) should be substantially covered to maximize the effectiveness of the "If an identification number is placed over the word(s) on a placard, the word identification number." Therefore, the Black cross-bones on the top corner of the diamond and the 6 on the bottom corner identifies that the PIH placard IAW 172.555 was used and the rule 49 CFR 172.332 (c) (6) as stated above indicates that this is allowed. In discussing i have that panel; however, what the carrier opted to use is also an approved method. this matter with Arch we concluded that the norm would have been to use the orange regarding the visibility and display of placards. In conclusion, the placards were In addition, 49 CFR 172.516 was reviewed and your comments have been noted legible even though order of placement or color contrast may be questionable. I 7/28/2005#

Page 5Page 4 of 4 hope you will continue to advise this office of any other potential discrepancies appreciated! identified on any of our shipments. Your team support and efforts are greatly Thanks, Janie G. Gallegos Defense Energy Support Center (DESC-MIP) Traffic Management Specialist Voice (210) 925-1558 Pager (210) 203-615? janie.gallegos@dla.mil 7/28/2005#

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