{"operation":"document","citation":"05-0252","title":"Uwchalan Township Police Department — 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":"05-0252 response to Uwchalan Township Police Department concerning 172.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0252.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0252.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0252","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050252.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nOCT 28 2005\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nAdministration\nHazardous Materials Safety\nSpecial Operations/Traffic Safety\nCPL F. Allen Mauger, Jr.\nRef No.: 05-0252\nUwchalan Township Police Department\n717 N. Ship Road\nExton, PA 19341-1946\nDear CPL Mauger:\nThis is in response to your September 30, 2005 letter and subsequent telephone\nconversation with Ben Supko of my staff requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). First, you ask if a cargo tank\nmotor vehicle transporting fuel oil may be placarded on the sides and rear with\ncombustible placards marked with \"UN1993\" and a \"fuel oil\" placard on the front.\nSecond, you ask if CORROSIVE placards with a white panel area in the center but no\nidentification number marked in the white panel area are acceptable for a non-bulk\nshipment.\nA cargo tank containing fuel oil, classed as a combustible liquid, must display\nCOMBUSTIBLE placards. In accordance with § 172.544(c), the placards may be\nmodified to read \"FUEL OIL\" rather than \"COMBUSTIBLE.\" Therefore, the placement\nof a COMBUSTIBLE placard with the words \"FUEL OIL\" on the front of the cargo tank\nis not a violation of the HMR. However, § 172.302(a) requires the identification number\nfor the material to be marked on each side and each end of a packaging with a capacity of\n3,785 L (1,000 gallons) or more. Since the COMBUSTIBLE placard with the words\n\"FUEL OIL\" is displayed on the front of the cargo tank and the identification number is\nnot marked on an orange panel or white square-on-point configuration (see § 172.332(b)),\nthe marking requirements in § 172.302(a) are not fulfilled.\nThe CORROSIVE placard must conform to the requirements in § 172.558, except that it\nor modified by removing the word \"CORROSIVE\" (see § 172.519(b)(3)). The placard\nmay be modified to display the identification number of the material (see § 172.332(c)),\nyou describe, a CORROSIVE placard with a blank white panel area in the center, does\nnot fulfill the requirements of § 172.558 or the exceptions mentioned above.\nI hope this information is helpful. Please contact us if you require additional assistance.\nief, Standards Development\nSce of Hazardous Materials Standards\n112.504\n050252\n\n<<<PAGE 2>>>\n\nUWCHLAN TOWNSHIP POLICE DEPARTMENT\nCHESTER\nCOUNTY PENNSYLVANIA\nSupko\nSeptember 30, 2005\n$172.504\nMr. John Gale\nChief, Standards Development\nPlacarding\nOffice of Hazardous Material Standards\nPipeline and Hazardous Materials\n02-0252\nSafety Administration\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nDear Mr. Gale,\nI am requesting clarification from your office on the two following matters:\n1. The first matter involved a cargo tank vehicle delivering combustible products. It displayed\ncombustible placards with 1993 markings in the placard on the sides and rear. At the same time,\nit displayed a combustible placard with the words \"fuel oil\" on the front. After reading your\ninterpretation dated June 13, 2005 to Sgt. David Feathers, you addressed mixing placards on\nnon-bulk shipments. Would this apply to this matter as well?\n2. The second matter involved a truck displaying corrosive placards with a white panel area in\nthe center for the UN number/marking. There were no UN numbers in the panels. While\nobserving the truck crossing the scales, it was very hard to determine if they were placards and\nwhat kind they were until the vehicle was very close. The driver stated that his company permits\nthis practice in case they pickup a bulk shipment. He would then write the proper UN number in\nthe panel area. The white panel area (3.9 inches x 8.5 inches) takes up approximately 28% of\nthe placard area without providirg any additional information. This was most noticeable on the\nblack/white corrosive placard.\nAdditionally, if a violation exists, what section/subsection would you cite for each of the\nexamples?\nYour assistance in this matter would be greatly appreciated.\nSincerely,\nFAlalleze\nSpecial Operations/Traffic Safety\nF. Allan Mauger Jr., Corporal\n717 N. SHIP ROAD • EXTON, PENNSYLVANIA 19341-1946 • (610) 363-6947 • FAX (610) 524-1088","truncated":false,"body_characters":4174}