Minnesota Department of Transportation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUL 3 1 2006 Mr. Michael Ritchie Minnesota Department of Transportation Ref. No. 06-0122 Office of Freight and Commercial Vehicle Operations Mail Stop 460, Room 121 395 John Ireland Blvd. St. Paul, MN 55155 Dear Mr. Ritchie: This is in response to your letter requesting clarification of the Hazardous Materials fuel and fuel oils mixed with vegetable and animal oils, and gasoline mixed with Regulations (HMR; 49 CFR Parts 171-180) regarding proper shipping names for diesel denatured ethanol. The first product (B-2) is 98% fuel oil/diesel fuel blended with 2% vegetable and animal oils. The third product is gasoline blended with at least 1.0% vegetable and animal oils. The second product (B-20) is 80% fuel oil blended with 20% animal oils have flash points meeting Class 3 (flammable) or combustible liquid denatured ethanol. You state that data indicates the fuel oils blended with vegetable and definitions under the HMR. You also state that the shipping papers for these materials do You ask which shipping names are most appropriate for these products. not indicate that the material is mixed, rather, they show the materials listed separately. 192.101 (E)(0) (i)(A) 060122#

Page 2Currently, the most appropriate proper shipping name for gasoline mixed with not more would be appropriately assigned to gasoline that is not mixed with other hazardous materials. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention#

Page 3DEPART Minnesota Department of Transportation THAT OK TRANS Mail Stop 420 Office of Freight and Commercial Vehicle Operations 1110 Centre Pointe Curve Tel: 651/405-6060 Mendota Heights, MN 55120-4152 Fax: 651/405-6082 M'Inture 3172.101 Proper Shipping Name May 3, 2006 06-0122 US Department of Transportation Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration Mr. Edward T. Mazzullo PHH-10 400 Seventh Street SW Washington, DC Re: Proper shipping names for alternative fuels. Dear Mr. Mazzullo, office show a boiling point of >400° F and a flash point of 321° F PMCC. The MSDS shows Biodiesel is not regulated by USDOT as a hazardous material. Diesel fuel/fuel oils blended with the Biodiesel material are shipped at several different and 80% fuel oil. Data received by my office indicates the blended products have flash blending rates. B-2 is 2% Biodiesel and 98% fuel oil/diesel fuel. B-20 is 20% Biodiesel points that would make them flammable liquids or combustible liquids by USDOT definitions. information that some of the blended products are being shipped and transported with The fuel oils and Biodiesel are splash blended and then distributed. My office has shipping papers showing a hazardous materials description for diesel fuel or fuel oil or the first line, and the entry Biodiesel or Fatty acid esters on a second line. There is no indication on the document that the product is a blend of the two materials. The blended materials are shipped and transported in cargo tanks. If the blended materials are a solution of a hazardous material and a non-hazardous material, should the proper shipping name be diesel fuel solution or fuel oil solution, as required in 49 CFR 172.101 (c) (10)? An equal opportunity employer#

Page 4ethanol by volume. The hazardous materials table assigns the proper shipping name Most gasoline offered for sale in Minnesota is required to be at least 10% denatured Gasohol to gasoline mixed with not more than 20% ethyl alcohol. Is Gasohol the required name for this material, or can the shipper identify it as Gasoline on a hazardous materials shipping paper! Michel Flie Thank you for your assıstance Michael Ritchie Hazardous Materials Specialist Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations 395 John Ireland Boulevard Mail Stop 460, Room 121 Michael.Ritchie@dot.state.mn.us St. Paul, MN 55155#