{"operation":"document","citation":"05-0189","title":"NASA-White Sands Test Facility — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-10-28","effective_on":null,"summary":"05-0189 response to NASA-White Sands Test Facility concerning 172.504, 172.555.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0189.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0189.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0189","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050189.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nHazardous Materials Safety\nAdministration\nOCT 28 2005\nMr. Paul Goodwin\nRef No.: 05-0189\nTransportation Manager\nNASA-White Sands Test Facility\n12600 NASA Road\nLas Cruces, NM 88012\nDear Mr. Goodwin:\nThis responds to your July 28, 2005 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a closed\ntransport vehicle containing ten 650 pound cylinders of methylhydrazine, a Hazard Zone\nA poisonous by inhalation (PIH) material, must be placarded with the POISON\nINHALATION HAZARD placard provided in § 172.555. In addition, you ask if the\ntransport vehicle must be marked in accordance with §§ 172.313.\nAs provided in § 172.504(e), a transport vehicle containing any amount of Division 6.1,\nHazard Zone A or B material (i.e., methylhydrazine) must display the placards depicted\nin § 172.555 on each side and each end. In addition, because your transport vehicle\ncontains more than 2,205 pounds of methylhydrazine, it must be marked on each side and\neach end with \"UN 1244\" (§ 172.313(c)). The identification number must be displayed\non orange panels or placards as specified in § 172.332, or on white square-on-point\nconfigurations as prescribed in § 172.336(b).\nAlso note that § 172.313(a) requires the words \"Inhalation Hazard\" to be marked in\nassociation with required labels, placards, and shipping name when appropriate. This\nrequirement applies to the package itself. Therefore, the words \"Inhalation Hazard\" must\ne marked in association with the label on non-bulk packagings; bulk packaging such as\nargo tank or rail tank car must be marked with the words \"Inhalation Hazard\" ir\napear on the lach or placarl, this marking is id re Wiren the words \"inhalation Hazard\"\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\n172:504\nChief, Standards Nevelopmen\nlaterials Standards\n172555\n172.333\n050189\n\n<<<PAGE 2>>>\n\nPage 1 of 4\nDrakeford, Carolyn <PHMSA>\nSupko\nFrom: Gorsky, Susan <PHMSA>\nSent:\nThursday, July 28, 2005 9:16 AM\n§172.504\nTo:\nDrakeford, Carolyn <PHMSA>\nSubject: FW: Placard problem\n$172.555\nCould you put this into the interp system please? Thanks.\n§112.333'\nFrom: Paquet, Ryan <FMCSA>\n-----Original Message-----\nPlacarding Marting\nTo: Gorsky, Susan <PHMSA>\nSent: Thursday, July 28, 2005 7:31 AM\nCylinder 85-0189\nSubject: FW: Placard problem\nSusan, could you please have someone look at the following flood of emails and let me know\nwhat they make of it?\nThank you very much!\nRyan\n-----Original Message-..--\nFrom: Goodwin, Paul [mailto:pgoodwin@smtp3.wstf.nasa.gov]\nSent: Wednesday, July 27, 2005 5:53 PM\nCc: ###Gary Lindsey (lindseyg@all-pak.com); ####Mike Brennan\nTo: Paquet, Ryan; Lynch, Tom <PHMSA>\nSubject: FW: Placard problem\nnot to beat a dead horse BUT..I have been going round and round with several people in the aerospace and\nLady and Gentlemen,\ntaught and I trust your opinions so here is a scenario:\nhazmat transportation community for months about a placarding interpretation that differs from what I have been\nHow would you placard Methylhydrazine for a non bulk shipment of 10\ncylinders ( 650 Ibs. a piece) in an enclosed van going from one place\n(Worcester, MA) directly to another place (Trenton, NJ).\nI checked the DOT exemption to see if there was any relief from placarding regulations and there was not!\nDOT has already stated his interpretation for another previous shipment of MMH as follows:\n\"Because this material is a 6.1, Hazard Zone A (therefore found in Table 1 of 172.504) the\ntransport vehicle must be placarded when any amount of the material is transported. As\nplacard (see below, the words \"Inhalation Hazard must be on the placard). Also, 172.516 (c)\nshown in Table 1, the placard required is found in 172.555. As you can see, this is a specific\n(7) states: \"Affixed to a background of contrasting color, or must have a dotted or solid line\nouter border which contrasts with the ba. kground color (My opinion - Silver is not contrasting\nenough). \"\nOther people in the aerospace and hazmat transportation community, are citing 172.313 and or 172.332 :\n§172.313 Poisonous hazardous materials. In addition to any other markings required by this\n7/28/2005\n\n<<<PAGE 3>>>\n\nPage 2 of 4\nsubpart\nc) A transport vehicle or freight container containing a material poisonous by inhalation in non-bulk packages shall be\nhazardous material in the § 172.101 Table, subject to the following provisions and limitations:\nmarked, on each side and each end as specified in § 172.332 or § 172.336, with the identification number specified for the\n2) The transport vehicle or freight container is loaded at one facility with 1,000 kg (2,205 pounds) or more aggregate gross\n1) The material is in Hazard Zone A or B;\n(3) If the transport vehicle or freight container contains more than one material meeting the provisions of\nweight of the material in non-bulk packages marked with the same proper shipping name and identification number; and\nthis paragraph (c), it shall be marked with the identification number for one material, determined as\nfollows: (i) For different materials in the same hazard zone, with the identification number of the\nmaterial having the greatest aggregate gross weight; and (ii) For different materials in both Hazard\nZones A and B, with the identification number for the Hazard Zone A material.\n§172.332 Identification number markings.\nmarkings must be displayed on orange panels or placards as specified in this section, or on white square-or-point\n(a) General. When required by §§ 172.301, 172.302, 172.313, 172.326, 172.328, 172.330, or 172.331, identification number\n(b) Orange panels. Display of an identification number on an orange panel shall be in conformance with the following:\nconfigurations as prescribed in § 172.336(b).\nborder. The identification number shall be displayed in 100 mm (3.9 inches) black Helvetica Medium numerals on the orange\n(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\n(2) The orange panel may be made of any durable material prescribed for placards in $172.519, and shall be of the orange\npanel. Measurements may vary from those specified plus or minus 5 mm (0.2 inches).\nthan 18 points high.\n(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\n(4) Except for size and color, the orange panel and identification numbers shall be as illustrated for Liquefied petroleum gas:\n1075\n(1) The identification number shall be displayed across the center area of the placard in 88mm (3.5 inches) black Alpine\n(c) Placards. Display of an identification number on a hazard warning placard shall be in conformance with the following:\nGothic or Alternate Gothic No. 3 numerals on a white background 100 mm (3.9 inches) high and approximately 215 mm (8.5\n(2) The top of the 100 mm (3.9 inches) high white background shall be approximately 40mm (1.6 inches) above the placard\ninches) wide and may be outlined with a solid or dotted line border.\nhorizontal center line.\n(3) An identification number may be displayed only on a placard correspor ding to the primary hazard class of the hazardous\n(5) The name of the hazardous material and the hazard class may be shown in letters not more than 18 points high\n(6) If an identification number is placed over the words) on a placard, the word(s) should be substantially covered to\nmmediately within the upper border of the space on the placard bearing the identification number of the material\nmaximize the effectiveness of the identification number.\n(d) Except for size and color, the display of an identification number on a placard shall be as illustrated for Acetone:\n7/28/2005\n\n<<<PAGE 4>>>\n\nPage 3 of 4\n-\n1%\n1090\n3½\n2%\n-\n3\n14\nspen• DOT\n13\nHELP?\nAre there several ways to placard this shipment ?\nShould I think about sending this question onto Mr. Mazzullo C US DOT\nLetters of Interpretation of the HMR?\nthank you for your expertise and intellect;\nSincerely\n505-524-5781\nPaul Goodwin, Transportation Manager\nFrom: Gallegos, Janie (DESC) [mailto:Janie.Gallegos@dla.mil]\nTo: Goodwin, Paul\nSent: Tuesday, July 19, 2005 10:37 AM\nSubject: FW: Placard problem\nCc: Mokry, Catherine (DESC)\nGood Morning\nThank you for bringing your concerns to my attention and for providing the photos\nPaul,\nthey had offered the orange panel but that the carrier\nthey were instrumental with our review of the regulations.\nstated they had the placards\n#### informed me that\nIn reviewing rule 49 CFR 172.332(a) it identifies three options to display the\npoint configuration.\ndentification number markings via orange panel, placards or on white square-on-\nThe carrier opted to use the placard method. Please see 4'\nCFR 172.332 (c) (6) which also states,\n(s) should be substantially covered to maximize the effectiveness of the\n\"If an identification number is placed over the word(s) on a placard, the word\nidentification number.\"\nTherefore, the Black cross-bones on the top corner of the diamond and the 6 on the\nbottom corner identifies that the PIH placard IAW 172.555 was used and the rule 49\nCFR 172.332 (c) (6) as stated above indicates that this is allowed. In discussing\ni have that\npanel; however, what the carrier opted to use is also an approved method.\nthis matter with Arch we concluded that the norm would have been to use the orange\nregarding the visibility and display of placards. In conclusion, the placards were\nIn addition, 49 CFR 172.516 was reviewed and your comments have been noted\nlegible even though order of placement or color contrast may be questionable. I\n7/28/2005\n\n<<<PAGE 5>>>\n\nPage 4 of 4\nhope you will continue to advise this office of any other potential discrepancies\nappreciated!\nidentified on any of our shipments. Your team\nsupport and\nefforts\nare greatly\nThanks,\nJanie G. Gallegos\nDefense Energy Support Center (DESC-MIP)\nTraffic Management Specialist\nVoice (210) 925-1558\nPager (210) 203-615?\njanie.gallegos@dla.mil\n7/28/2005\n\n<<<PAGE 6>>>\n\n\n\n<<<PAGE 7>>>\n\n1117","truncated":false,"body_characters":10172}