MHF Logistical Solutions — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety MAY -3 2006 Mr. Kurt Colburn Director of Technical Services Ref. No. 05-0311 MHF Logistical Solutions Cranberry Township, PA 16066 800 Cranberry Woods Drive, Suite 450 Dear Mr. Colburn: This is in response to your December 5, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification regarding placarding requirements for multiple bulk packages on single transport vehicle. load device, transport vehicle or railcar containing any quantity of a hazardous material Except as otherwise provided in the HMR, each bulk packaging, freight container, unit must be placarded on each side and each end with the types of placards specified in Subpart F of Part 172. The requirement to placard the motor vehicle may be met by the placards displayed on freight containers or portable tanks (§ 172.516). However, except as provided in $ 172.336, a placard bearing an identification number may not be used to meet the eauirements of Subpart F of Part 172 unless it is the correct identification number for al of the hazardous materials of the same class in the transport vehicle or freight containe on which it is displayed. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, John A. Gale Office of Hazardous Materials Standards Chief, Standards Development 172.504 172.508 050311#

Page 2Learu §172:504 5172.508 CITICAL SOLUTIONS Placarding 05-031| 800 Cranberry Woods Drive, Suite 450, Cranberry Township, PA 16066 T 724.772.9800 F 724.772.9850 W www.mhils.com Mr. Edward Mazzullo Director of Hazmat Standards USDOT/PHMSA, Suite 8422 400 7 Street, SW Office of Hazardous Materials Safety Washington, DC 20590-3012 December 5, 2005 SUBJECT: Clarification of Placarding Requirements for Cargo Containers on Railcars Dear Mr. Mazzullo, This letter requests clarification of the placarding requirements for cargo containers (and bulk intermodal containers) shipped by rail. affixed to all four sides of the rail car, and that this requirement may be met by placards Regulation 49 CFR 172.508(a) states that when placards are required, they must be placed on the packages. In addition, 49 CFR 173.504(a) states that placards are required for bulk packages, freight containers, or rail cars. car. Ín this arrangement, a single placard would appear on the sides, front, and rear of the rail car. However, the individual packages might be placarded on only one side (or not at all). 2. Similarly, if two bulk packages are shipped by truck, please confirm it is permissible to distribute the 4 required placards among the two packages so tha he 4 sides of the truck are placarded as required#

Page 33. An alternative interpretation of 172.508(a) is that cargo containers must be single conveyance. In this arrangement, the front and rear placards of adjoining placarded on all four sides, even when transported in groups of two or more on a containers are not readily visible, and placards on the sides of the individual containers amount to redundant placarding of the conveyance. Please confirm that such redundant placarding is permissible, but not required. Your consideration of this request is appreciated. Please feel free to call me at (724) 772- information to consider this request. 9800, ext. 5560 if you have any questions about this letter, or require any additional Respectfully submitted, MHF Logistical Solutions Kurt Colborn Director of Technical Services#