{"operation":"document","citation":"06-0210","title":"Dufour Petroleum LP — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-11-07","effective_on":null,"summary":"06-0210 response to Dufour Petroleum LP concerning 172.315, 172.328.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0210.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0210.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0210","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060210.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nNOV 7 2006\n0O Seventh Street, S.\nVashington, D.C. 2059\nPipeline and\nHazardous Materials Safety\nAdministration\nSafety Supervisor\nMr. Don Ladner\nRef. No. 06-0210\nP.O. Box 1184\nDufour Petroleum LP\nPetal, MS 39465\nDear Mr. Ladner:\nrequirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180)\nThis is in response to your September 14, 2006 letter requesting clarification of the\nQ1. Are we required to mark each of our cargo tanks with the NON-ODORIZED or\nNOT ODORIZED marking by September 30, 2006, or only the cargo tarks\ntransporting non-odorized LPG?\nAl.\nSection 172.328 requires that, after September 30, 2006, no person may offer for\ntransportation or transport a cargo tank containing unodorized LPG as authorized in\n§ 173.315(b)(1) unless it is legibly marked NON-ODORIZED or NOT\nODORIZED on two opposing sides near the marked proper shipping name as\nequirement does not specifically state that this marking may appear on a carg\nank used for both odorized and non-odorized LPG; however, it is not prohibite\nQ2.\nmarking on cargo tanks?\nWhat is the height requirement for the NON-ODORIZED or NOT ODORIZED\nA2.\nSection 172.302 requires the NON-ODORIZED or NOT ODORIZED marking to\ninches) for rail cars.\nhave a width of at least 6.0 mm (0.24 inch) and a height of at least 100 mm (3.9\nQ3.\nIs the NON-ODORIZED or NOT ODORIZED marking required to be on two\nplacards?\nopposing sides of the cargo tank near the proper shipping name, or near the\n172.328(6)\n172.315\n060210\n\n<<<PAGE 2>>>\n\nA3.\nSee Al.\nQ4.\nAre we required to mark each of our rail tank cars with the NON-ODORIZED or\nNOT ODORIZED marking by September 30, 2006, or only the tank cars\ntransporting non-odorized LPG?\nA4.\nransportation or transport a tank car or multi-unit tank car tank containing\ninodorized LPG unless it is legibly marked NON-ODORIZED or NOT\ntank car tank used for both unodorized and odorized LPG.\nODORIZED or NOT ODORIZED marking may appear on a tank car or multi-unit\nQ5.\nWhat is the height requirement for the NON-ODORIZED or NOT ODORIZED\nmarking on rail tank cars?\nA5.\nSection 172.302 requires that the NON-ODORIZED or NOT ODORIZED\nleast 100mm (3.9 inches) for rail cars.\nmarking must have a width of at least 6.0 mm (0.24 inch) and a height of at\n06.\nIs the NON-ODORIZED or NOT ODORIZED marking required to be on two\nplacards?\nopposing sides of a rail tank car near the proper shipping name, or near the\nA6. See A4.\nI trust this satisfies your inquiry.\nSincerely,\nsom a Gale\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nFoster\nPage 1 of 1\n§172.328(6)\nDrakeford, Carolyn <PHMSA>\nMarkings\nFrom: INFOCNTR <PHMSA>\nSent: Thursday, September 14, 2006 5:04 PM\n06-0210\nTo:\nDrakeford, Carolyn <PHMSA>\nSubject: FW: 172.328(b)(e)\nMr. Edward Mazz ulld,\na formal interpretation to clear up some questions that are unclear to me.\nIn regards to the regulation 172.328(b) (e), NON-ODORIZED marking on cargo tanks containing LPG, I would like\nname or near the placards?\nI will also like a formal interpretation pertaining to the same questions as above in regards to our Rail Cars hauling\nLPG. Is it correct to have the markings no less than 3.9\" in height on two opposing sides near the proper shipping\nname or near the placards?\nDon Ladner\nDufour Petroleum LP\nSafety Supervisor\nThanks,\nPetal, Ms. 39465\nP.O. Box 1184\nDon Ladner\n601-583-9991 Ext.238\n9/15/2006","truncated":false,"body_characters":3426}