# Uwchalan Township Police Department — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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>>>

of Transportation
U.S. Department
OCT 28 2005
400 Seventh Street, S.W.
Washington, D.C. 20590
Pipeline and
Administration
Hazardous Materials Safety
Special Operations/Traffic Safety
CPL F. Allen Mauger, Jr.
Ref No.: 05-0252
Uwchalan Township Police Department
717 N. Ship Road
Exton, PA 19341-1946
Dear CPL Mauger:
This is in response to your September 30, 2005 letter and subsequent telephone
conversation with Ben Supko of my staff requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180). First, you ask if a cargo tank
motor vehicle transporting fuel oil may be placarded on the sides and rear with
combustible placards marked with "UN1993" and a "fuel oil" placard on the front.
Second, you ask if CORROSIVE placards with a white panel area in the center but no
identification number marked in the white panel area are acceptable for a non-bulk
shipment.
A cargo tank containing fuel oil, classed as a combustible liquid, must display
COMBUSTIBLE placards. In accordance with § 172.544(c), the placards may be
modified to read "FUEL OIL" rather than "COMBUSTIBLE." Therefore, the placement
of a COMBUSTIBLE placard with the words "FUEL OIL" on the front of the cargo tank
is not a violation of the HMR. However, § 172.302(a) requires the identification number
for the material to be marked on each side and each end of a packaging with a capacity of
3,785 L (1,000 gallons) or more. Since the COMBUSTIBLE placard with the words
"FUEL OIL" is displayed on the front of the cargo tank and the identification number is
not marked on an orange panel or white square-on-point configuration (see § 172.332(b)),
the marking requirements in § 172.302(a) are not fulfilled.
The CORROSIVE placard must conform to the requirements in § 172.558, except that it
or modified by removing the word "CORROSIVE" (see § 172.519(b)(3)). The placard
may be modified to display the identification number of the material (see § 172.332(c)),
you describe, a CORROSIVE placard with a blank white panel area in the center, does
not fulfill the requirements of § 172.558 or the exceptions mentioned above.
I hope this information is helpful. Please contact us if you require additional assistance.
ief, Standards Development
Sce of Hazardous Materials Standards
112.504
050252

<<<PAGE 2>>>

UWCHLAN TOWNSHIP POLICE DEPARTMENT
CHESTER
COUNTY PENNSYLVANIA
Supko
September 30, 2005
$172.504
Mr. John Gale
Chief, Standards Development
Placarding
Office of Hazardous Material Standards
Pipeline and Hazardous Materials
02-0252
Safety Administration
400 Seventh Street, S.W.
Washington, D.C. 20590
Dear Mr. Gale,
I am requesting clarification from your office on the two following matters:
1. The first matter involved a cargo tank vehicle delivering combustible products. It displayed
combustible placards with 1993 markings in the placard on the sides and rear. At the same time,
it displayed a combustible placard with the words "fuel oil" on the front. After reading your
interpretation dated June 13, 2005 to Sgt. David Feathers, you addressed mixing placards on
non-bulk shipments. Would this apply to this matter as well?
2. The second matter involved a truck displaying corrosive placards with a white panel area in
the center for the UN number/marking. There were no UN numbers in the panels. While
observing the truck crossing the scales, it was very hard to determine if they were placards and
what kind they were until the vehicle was very close. The driver stated that his company permits
this practice in case they pickup a bulk shipment. He would then write the proper UN number in
the panel area. The white panel area (3.9 inches x 8.5 inches) takes up approximately 28% of
the placard area without providirg any additional information. This was most noticeable on the
black/white corrosive placard.
Additionally, if a violation exists, what section/subsection would you cite for each of the
examples?
Your assistance in this matter would be greatly appreciated.
Sincerely,
FAlalleze
Special Operations/Traffic Safety
F. Allan Mauger Jr., Corporal
717 N. SHIP ROAD • EXTON, PENNSYLVANIA 19341-1946 • (610) 363-6947 • FAX (610) 524-1088
- **truncated:** false
- **body characters:** 4174