REG Scan — Hazardous Materials Safety Interpretation

Page 1S. Departme Transportatic Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazarcious Materials Safety Administration MAR 31 2006 Mr. Russ Shanahan Ref. No.: 06-0050 800 West Fourth Street REG Scan Williamsport, PA 17701 Dear Mr. Russ Shanahan: This responds to your letter dated February 14, 2006 regarding the marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to the display of identification number marking on a closed transport vehicle containing multiple bulk packages. Q1. Are two "UN1993" identification number markings required to be displayed on a closed transport vehicle containing two bulk packagings of a material described as "Flammable liquid, n.o.s., 3, UN 1993, PG 1." Al. For a bulk packaging contained in or on a transport vehicle or in a freight container, if the identification number marking on the bulk packaging is not visible, the transport vehicle or freight container must be marked on each side and each end with the identification number specified for the material in the § 172.101 Table (See § 172.332). identification number and displayed as required by § 172.332 on each side and As specified in § 172.302(a), a bulk packaging must be marked with the each end of the bulk packaging, if the capacity of the packaging is 3,785 L (1,000 gallons) or more, or on two opposing sides, if the packaging has a capacity of les: han 3,785 L (1,000 gallons). Additional requirements for marking bull packagings, such as a portable tank, cargo tank, tank car and multi-unit tank car tank, and other bulk packaging (e.g., IBCs) are prescribed in §§ 172.326, 172.328, Q2. Would the answer to "Ql" change if the products had the same technical names? A2. No. Q3. Are the two identification number markings, "UN1993" and "NA1993", required to be displayed on a closed transport vehicle containing two bulk packagings of 172.302 060050 172.331#

Page 2materials described as "Flammable liquid, n.o.s., 3, UN 1993, PG 1" and "Combustible liquid, n.o.s, Combustible liquid, NA 1993, PG III." A3. See answer "Al". In this case, the identification numbers are essentially the same. The marking "UN1993" is used for both domestic and international transportation, while the marking "NA1993" may only be used for domestic transportation. with § 172.504. Each bulk packaging must be placarded in accordance I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely: John A. Gale Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Engram $172.302 §172.331 Markings ::::: REGSCan. the smarter way to know 86-0050 Feb 14, 2006 Director of Hazardous Materials Standards Mr. Edward T. Mazzullo 400 7th St South-West US DOT/PHMSA (PHH-10) Washington, DC: 20590-0001 RE: Letter of Interpretation - Multiple Bulk ID Marking Requirements Dear Mr. Mazzullo, each of these questions, please assume that each bulk package is contained within a truckload and no part of the bulk I would appreciate a clarification on vehicle marking requirements when multiple bulk packages are on board. For package is exposed from the outside. 1. Given this load: Flammable Liquid, n.o.s., 3, UN1993, PG I, Bulk Flammable Liquid, n.o.s., 3, UN1993, PG I, Bulk Are two 1993 markings required on the vehicle, or is only one 1993 marking required on the vehicle? 2. Would the answer to question #1 change based on whether the products had the same technical names? 3. Given this load: Flammable Liquid, n.o.s., 3, UN1993, PG I, Bulk Are two 1993 markings required on the vehicle, or is only one 1993 marking required on the vehicle? Combustible Liquid, n.o.s., Comb Liq, NA1993, PG III, Bulk Thank you for your consideration. Sincerely, Russ Shanahan : .+ • :0! ....#