Georgia Department of Public Safety — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration JUL 28 2006 Captain Bruce Bugg Motor Carrier Compliance Division Georgia Department of Public Safety Ref. No.: 06-0143 P.O. Box 1456 Atlanta, GA 30371-1456 Dear Captain Bruce Bugg: This is in response to your letter dated June 29, 2006, regarding the placarding requirements for combustible liquids in intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification of a previous letter from PHMSA to a Mr. Paul M. Bomgardner, dated August 14, 1995. Your questions are summarized and answered below. shipper placard the IBC, since there is no specified "Combustible liquid label in Q1. A shipper offers an IBC filled with "Combustible liquid, n.o.s." Must the the HMR? Al. The answer is yes. Combustible liquids transported in a bulk packaging must "Combustible liquid" label specified in the HMR, this exception is not authorized for a bulk packaging containing a combustible liquid. "Flammable liquid" label and replace the word "Flammable" with "Combustible"? Q2. May the shipper use a label of the same size, shape and design as a e placarded. A bulk packaging placarding exception authorized in § 172.514(c 12. The answer is no. Combustible liquids transported in a bulk packaging mus allows an IBC to be placarded on two opposing sides or, alternatively, labeled in 'Combustible liquid" label specified in the HMR, this exception is not authorize iccordance with Part 172, Subpart E of the HMR. However, because there is n disp ayay the the Be use "Flammable" placards in place of "Combussible" placards 172.504(f)E) 060143 172.514 (c)#

Page 2A3. The answer is no. In accordance with § 172.504(f)(2) a "FLAMMABLE" ortable tank or a compartmented tank car which contains both flammable an lacard may only be used in place of a "COMBUSTIBLE" placard on a cargo tank combustible liquids. This provision does not apply to IBCs. closed vehicle (van-type trailer or truck) in place of the "Combustible" placards? Q4. May a carrier transporting IBCs use "Flammable" placards on the outside of a A4. The answer is no. (See response to Q3 above.) I hope this information is helpful. Please contact us if you need additional assistance. Sincerely, that batt? Senior Transportation Specialist Charles E. Betts Office of Hazardous Materials Safety#

Page 3Page 1 of 2 Drakeford, Carolyn <PHMSA> From: INFOCNTR <PHMSA> Sent: Thursday, June 29, 2006 8:58 AM BAH To: Drakeford, Carolyn <PHMSA> §172.50+(Xz) Subject: FW: Request for updated clarification $172.514(c) Placardin -Original Message-.. From: O.Bruce Bugg [mailto:obbugg@gsp.net] 11-0143 Sent: Wednesday, June 28, 2006 12:56 PM To: INFOCNTR <PHMSA> Cc: PaulB; Billings, Delmer <PHMSA> Subject: Request for updated clarification This e-mail requests a written clarification regarding 172.504 and 172.514, partially to to update the clarification issued in August 1995 (reproduced below). 1. A shipper offers an Intermediate Bulk Container filled with "Combustible liquid, n.o.s." Must the shipper placard the IBC, since ere is no specified "combustible liquid" label? words with the word "combustible," or "Combustible liquid?" 2. May the shipper use a label of the same size, shape and design as a "Flammable liquid" label and replace the 3. May the shipper use "flammable" placard(s) in place of "Combustible" placard(s) displayed on the IBC? Lala orca in place portie Comics ue Flares Trip carton the outed talent pries gian. Previous guidance: Hazardous Materials Specialist Mr. Paul M. Bomgardner 2200 Mill Road American Trucking Associations Alexandria, Virginia 22314-4677 a van-type trailer which contains a portable tank that is already placarded COMBUSTIBLE and not visible from This is in response to your letter regarding using a FLAMMABLE placard in place of a COMBUSTIBLE placard on the outside? The scenario you presented is as follows: COMBUSTIBLE placard and an orange panel with the appropriate identification number. This is placed inside a A 250 gallon portable tank contains paint that is a combustible liquid. The portable tank displays a identification number on orange panels on all 4 sides of the trailer. The trailer is then placarded FLAMMABLE. van trailer and the outside of the trailer is then marked as required by § 172.326 utilizing the option to display the Section 172.504(f)(2) permits a FLAMMABLE placard to be used on a cargo tank or portable tank in place of a Since the motor carrier is placarding for the portable tank inside the van trailer, is this permiss ble? COMBUSTIBLE placard during transportation of materials classed as flammable liquids and combustible liquids. trailer, it is permissible to place a FLAMMABLE placard on the outside of the van trailer for purposes of Although the cargo tank or portable tank is placarded with a COMBUSTIBLE placard and placed inside of a van transportation. Section 172.504(f)(2) is intended primarily to relieve carriers who transport both flammable and 6/30/2006#

Page 4Page 2 of 2 who transport only combustible liquids. combustible liquids on different loads from having to change placards frequently. It may also be used by carriers I hope this information is helpful. If I can be of further assistance, please contact me. Sincerely, Delmer F. Billings Office of Hazardous Materials Standards Chief, Regulations Development File:172.504 Capt. Bruce Bugg Motor Carrier Compliance Division Georgia Department of Public Safety P.O. Box 1456 Atlanta, GA 30371-1456 Fax: 404.624.7295 Phone: 404.624.7211 or 7210 e-mail: obbugg(at)gsp.net [replace "(at)" with *@") 6/30/2006#