Minnesota Department of Transportation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and JAN 31 2007 Administration Mr. Michael Ritchie Ref. No. 06-0203 Hazardous Materials Specialist 395 John Ireland Boulevard Minnesota Department of Transportation Mail Stop 460, Room 121 St. Paul, MN 55155 Dear Mr. Ritchie: This is in response to your August 29, 2006 letter requesting clarification of the marking requirements for a compartmented cargo tank under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that most bulk transport companies in your region display identification numbers on placards and do not utilize orange panels or identification numbers on hazard warning placards. white square-on-point configurations. Therefore, this letter addresses the display of Your questions pertain to a cargo tank equipped with four compartments. Compartment #1 contains "Gasoline, UN1203"; compartment #2 contains "Diesel fuel, NA1993"; compartment #3 contains "Denatured alcohol, NA1987"; and compartment #4 contains "Gasoline, UN1203". Provided no exceptions are utilized, a compartmented cargo tank containing multiple Class 3 materials must be marked with the appropriate identification number for each different hazardous material on both sides and both ends in accordance with § 172.332. In this case, a Class 3 placard displaying UN number 1203, a Class 3 placard displaying NA number 1993, and a Class 3 placard displaying NA number 1987 nust appear on both sides and both ends of the cargo tank. The placards displaying : dentification numbers do not have to appear in any particular order. Q1. 3§ 172.336(c)(1) and 172.336(c)(4)? Under this scenario, the compartmented cargo tank May the compartmented cargo tank utilize the exceptions provided in both would display on each side a single Class 3 placard with UN number 1203 to identify the identits of compare stander a 3: and ingle plas piac spin 8710 number 1203 to identify the contents of compartment #4. A single Class 3 placard "without identification numbers would be displayed on the front and the rear of the cargo Al. tank containing hazardous materials with different identification numbers is excepted The answer is yes. In accordance with § 172.336(c)(1), a compartmented cargo from the requirement to display identification numbers on the front and rear (i.e., ends) of 113.336 c) 060203#

Page 2the cargo tank when the identification numbers are displayed on the sides of the tank in the same sequence as the compartments containing the materials they identify. Moreover, in accordance with § 172.336(c)(4), identification numbers are not required for each of the different petroleum distillate fuels in a compartmented cargo tank if the identification number for the liquid petroleum distillate fuel having the lowest flash point is displayed. May the compartmented cargo tank utilize the exception provided in § 172.336(c)(4)? Under this scenario, the cargo tank would display on each side one Class 3 placard with UN number 1203 and one Class 3 placard with NA number 1987. A2. Again, the answer is yes. In accordance with § 172.336(c)(4), identification compartmented cargo tank if the identification number for the petroleum distillate fuel numbers are not required for each of the different petroleum distillate fuels in a displayed on the sides of the cargo tank in the same sequence as the compartments with the lowest flash point is displayed. However, because the markings are not identification numbers representing each hazardous material must be displayec. on the containing the materials they identify, additional hazard warning placards with ends of the cargo tank. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, 4 ti Edward T. Mazzullo Director, Office of Hazardous Materials Standards#

Page 3Minnesota Department of Transportation 395 John Ireland Blvd. Office of Freight and Commercial Vehicle Operations Leary St. Paul, MN 55155-1899 $ 173.336 Markings August 29, 2006 06.0203 United States Department of Transportation Pipeline and Hazardous Materials Safety Administration Office of Hazardous Materials Standards Mr. Edward Mazzullo PHH-10 400 Seventh Street SW Washington, DC 20590 Re: Required Identification Number Marking on Cargo Tanks Dear Mr. Mazzullo, I have received your letter, Ref. No. 01-0082R, dated May 1, 2006, concerning; the use of alcohol and alcohol blends in a compartment of a cargo tank carrying petroleum fuels. the marking exception for petroleum distillate fuels in 49 CFR 172.336 when transporting Please clarify which markings are required on the sides of a multi-compartment cargo tank carrying petroleum fuels and alcohol in different compartments at the same time. Correct and consistent ID number markings on cargo tanks are critical issues for emergency responders. My office will be meeting with State Emergency Response Teams and both the petroleum and alcohol industries soon, and a prompt response would be appreciated. having mere than one compartment if hazardous materials having different ID numbers 49 CFR 172.336 (c) (1) states that ID numbers are not required on the ends of a unit are carried. In this circumstance, the ID numbers shall be displayed on the sides of the tank in the same sequence as the compartments containing the materials they identify. When transporting petroleum fuels and hazardous materials not eligible for the petroleum listillate fuel marking exception in different compartments, what marking is required? If wo consecutive compartments contain materials eligible for the petroleum fuels exceptions in § 172.336 (c) (4) and (5), may they be represented by one displayed ID n sequence? For example umber, or must each compartment be identified with a separate ID numbers on the side Compartment #1 Gasoline UN1203, compartment #2 Diesel Fuel NA 1993, compartment #3 denatured alcohol NA1987, compartment #4 gasoline UN1203. An equal opportunity employer#

Page 4In our region, and in these industries, most companies display ID numbers on placards and do not use orange panels or white-square on point devices. The regulation, and interpretations I have reviewed, make it clear that all four ID numbers may be displayed 3 placard displaying ID # 1203 to cover compartments 1 and 2, a Class 3 placard on each side, but what is required? May the sides of this tank show, in sequence, a Class for the fourth compartment? Is it legal to display on the sides only one Class 3 placard displaying ID number 1987 for compartment #3, and a third placard displaying ID #1203 displaying 1203 and one Class 3 placard with 1987? Are there any other allowable If you have any questions you can reach me at (651) 215-6326 or by e-mail at Michael.Ritchie@dot.state.mn.us. Yours truly, TickeRtter Michael Ritchie Hazardous Materials Specialist Minnesota Department of Transportation 395 John Ireland Boulevard Office of Freight and Commercial Vehicle Operations Mail Stop 460, Room 121 St. Paul, MN 55155#