Mr. John Stolpe — Hazardous Materials Safety Interpretation

Page 1Mr. John Stolpe Reference No.: 05-0276 4007 Marion Way Long Beach, CA 90807 Dear Mr. Stolpe: This responds to your letter requesting clarification of the marking and placarding requirements under the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180). You ask if a freight van containing non-bulk packages of a single hazardous material with an aggregate gross weight of 4,000 kg (8,820 Ibs.) must be marked with the identification number on each side and each end. You also submitted pictures of placarded freight containers displaying the identification (ID) number on the placards. In each picture, the placards are distorted because of the corrugated background of the freight container and only 2 digits of the ID number are clearly visible. You ask if this limited visibility of the ID numbers is acceptable under the HMR. In accordance with § 172.301, a transport vehicle or freight container containing only a single hazardous material in non-bulk packages must be marked on each side and each end with the identification number specified for the hazardous material in the § 172.101 Table. As to your second question, the HMR do not prohibit placards and ID number markings from being placed on a corrugated surface if the placards and markings comply with the visibility and display requirements specified in § 172.516. Specifically, each placard and ID marking must be clearly visible from the direction it faces. As shown in the photographs you submitted, the placards and markings are not clearly visible from the direction they face, thus, they do not conform to the HMR. I trust this satisfies your request. Sincerely, Hothe Z. Mtakell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.301 (a) 050276 172516#

Page 2400 7 Street SW Washington, DC 20590-0001 Dear RSPA Question: when transporting a hazardous material a non-bulk hazard at a single commodity over 8,820 pounds in a freight van, is the container required to be marked with the proper identification numbers on all four sides, as set in 172-301(a) CFR. If the answer is yes, then do the identification numbers must be all read from left to right? Being able to read all four numbers as set in 172-101 HMT, example if the freight van was filled with 72-drums of: Ethly phosphonothioic dichloride, anhydrous, 6.1, UN2927, PGI, 40,000 pounds. (No other hazards) If the numbers on a placard could not be read form left to right is this violation? And what would be the citing authority? Please look at provided photos clearly showing the ID-numbers affixed to the front of a freight van, which is not displaying all four numbers in the required sequence. Attached: four photos of ID-numbers not being properly displayed, photos were taken while standing in front of the freight vans. All freight vans had a single hazard, with nothing else being transported. Thank you for looking into this matter. John Stol 4007 Marion Way Long Beach, Ca 90807 (562) 572-6837 cell (562) 570-7209 work#

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Page 6ontainer with ID-Numbers not being displayed all four form left to right. Is this a vialtion? and what section to cite? 292#