{"operation":"document","citation":"06-0004","title":"Department of the Air Force — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-01-24","effective_on":null,"summary":"06-0004 response to Department of the Air Force concerning 172.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060004.pdf","body":"<<<PAGE 1>>>\n\nJAN 24 2006\nTSgt. Jesse Rubalcaba\nRef. No.: 06-0004\nCommand Section Evaluator\nDepartment of the Air Force\n20 AF/LGMM\n6610 Headquarters Drive\nF.E. Warren AFB, WY 82005-3943\nDear TSgt. Rubalcaba\nThis is in response to your letter requesting clarification of the placarding requirements\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically,\nyou ask if the exception from placarding in § 172.504(c), for less than 454 kg (1001 pounds)\naggregate gross weight of hazardous materials covered by Table 2 of § 172.504(e), applies to\nthe Division 2.2 material in cylinders. You indicate that the cylinders are loaded on a single\ntransport vehicle and weigh approximately 4,800 pounds.\nThe placarding exception in § 172.504(c) applies to the aggregate gross weight of all non-\nbulk packagings on a single transport vehicle that are covered by Table 2 of § 172.504(e)\nand do not fall under the provisions of § 172.505. As defined in § 171.8, the phrase \"gross\nweight\" is the weight of a packaging plus the weight of its contents.\nIn your scenario, the aggregate gross weight is equivalent to the aggregate weight of all\ncylinders and the Division 2.2 material they contain. Therefore, given that the aggregate\ngross weight of your cylinders is approximately 4,800 pounds, the transport vehicle must be\nplacarded.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nhe A. Gale\nOffice of Hazardous Materials Standards\n172.504\n060004\n\n<<<PAGE 2>>>\n\nTO: Office of Hazardous Material Standards,\nResearch and Special Programs Administration\nDHM-10, U.S. Department of Transportation\n400 7th Street SW, Washington, DC 20590-001\nFROM: 20 AF/LGMM\n6610 Headquarters Drive\nF. E. Warren AFB WY 82005-3943\nSUBJECT: Request interpretation of 49 CFR 172.504 General Placard Requirements\n1. A request of interpretation is needed for the following DOT placarding requirements,\n49 CFR 172, Subpart F., 172.504, (c). Step (c) states. \" placards are not required on-(1)\nA transport vehicles or freight container which contains less than 454 kg (1001 pounds)\naggregate gross weight of hazardous materials covered by table 2 of paragraph (e) of this\nsection.\"\n2. The transported vehicle in question is a 16 cylinder 4500 PSI cascade breathable\nbottled system weighing approximately 4800 Ibs. This syster is made up of 16 DOT\nbottles (P/N AC444), which are connected to each other using inter-connecting whips.\nThe air bottles are attached horizontally to an approved DOT storage rack using zinc\nplated steel cylinder retaining brackets. The entire unit is installed on an open flat bed\ntrailer.\n3. When in transport, all air bottles are closed and the remainder of the system is bled.\nThe unit is covered using a black canvas tarp which is used to protect the system from the\nelements. With the cover installed, the hazard is not identifiable to the public or first\nresponders.\n4. Different interpretations exist of whether the unit should be placarded. In one view,\ndue to the definition of gross weight, the bottle cylinder weight plus the content in the\nbottle accounts for the 1001 pound weight requirements, and it would require placarding.\nIn a second view, only the content in the bottle should account for the 1001 pound\nrequirements for placarding, and the unit would not require placards. Does this unit\nrequire placards or not?\nGUARDIANS OF THE HIGH FRONTIER\n\n<<<PAGE 3>>>\n\n5:000\nthis section.\"\nc. Section 171.8, Definitions and abbreviations: \"Gross weight or gross\nmass means the weight of the packaging plus the weight of its contents.\"\n\"Freight container means a reusable container having a volume of 64 cubic\nfeet or more, designed and constructed to permit being lifted with its\ncontents intact and intended primarily for containment of packages (in unit\nform) during transportation.\"\n6. Any questions regarding this letter can be directed to TSgt Jesse Rubalcaba,\n20 AF/LGMM, 307-773-5636, fax 307-773-5419. Thanks for your assistance.\nstink\nESSE RUBALCABA, TSgt, USAF\nCommand Section Evaluator\nTOTAL P.03","truncated":false,"body_characters":4085}