Uwchalan Township Police Department — Hazardous Materials Safety Interpretation

Page 1of 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 2UWCHLAN 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#