# Dufour Petroleum LP — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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>>>

of Transportation
U.S. Department
NOV 7 2006
0O Seventh Street, S.
Vashington, D.C. 2059
Pipeline and
Hazardous Materials Safety
Administration
Safety Supervisor
Mr. Don Ladner
Ref. No. 06-0210
P.O. Box 1184
Dufour Petroleum LP
Petal, MS 39465
Dear Mr. Ladner:
requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180)
This is in response to your September 14, 2006 letter requesting clarification of the
Q1. Are we required to mark each of our cargo tanks with the NON-ODORIZED or
NOT ODORIZED marking by September 30, 2006, or only the cargo tarks
transporting non-odorized LPG?
Al.
Section 172.328 requires that, after September 30, 2006, no person may offer for
transportation or transport a cargo tank containing unodorized LPG as authorized in
§ 173.315(b)(1) unless it is legibly marked NON-ODORIZED or NOT
ODORIZED on two opposing sides near the marked proper shipping name as
equirement does not specifically state that this marking may appear on a carg
ank used for both odorized and non-odorized LPG; however, it is not prohibite
Q2.
marking on cargo tanks?
What is the height requirement for the NON-ODORIZED or NOT ODORIZED
A2.
Section 172.302 requires the NON-ODORIZED or NOT ODORIZED marking to
inches) for rail cars.
have a width of at least 6.0 mm (0.24 inch) and a height of at least 100 mm (3.9
Q3.
Is the NON-ODORIZED or NOT ODORIZED marking required to be on two
placards?
opposing sides of the cargo tank near the proper shipping name, or near the
172.328(6)
172.315
060210

<<<PAGE 2>>>

A3.
See Al.
Q4.
Are we required to mark each of our rail tank cars with the NON-ODORIZED or
NOT ODORIZED marking by September 30, 2006, or only the tank cars
transporting non-odorized LPG?
A4.
ransportation or transport a tank car or multi-unit tank car tank containing
inodorized LPG unless it is legibly marked NON-ODORIZED or NOT
tank car tank used for both unodorized and odorized LPG.
ODORIZED or NOT ODORIZED marking may appear on a tank car or multi-unit
Q5.
What is the height requirement for the NON-ODORIZED or NOT ODORIZED
marking on rail tank cars?
A5.
Section 172.302 requires that the NON-ODORIZED or NOT ODORIZED
least 100mm (3.9 inches) for rail cars.
marking must have a width of at least 6.0 mm (0.24 inch) and a height of at
06.
Is the NON-ODORIZED or NOT ODORIZED marking required to be on two
placards?
opposing sides of a rail tank car near the proper shipping name, or near the
A6. See A4.
I trust this satisfies your inquiry.
Sincerely,
som a Gale
Chief, Standards Development
Office of Hazardous Materials Standards

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Foster
Page 1 of 1
§172.328(6)
Drakeford, Carolyn <PHMSA>
Markings
From: INFOCNTR <PHMSA>
Sent: Thursday, September 14, 2006 5:04 PM
06-0210
To:
Drakeford, Carolyn <PHMSA>
Subject: FW: 172.328(b)(e)
Mr. Edward Mazz ulld,
a formal interpretation to clear up some questions that are unclear to me.
In regards to the regulation 172.328(b) (e), NON-ODORIZED marking on cargo tanks containing LPG, I would like
name or near the placards?
I will also like a formal interpretation pertaining to the same questions as above in regards to our Rail Cars hauling
LPG. Is it correct to have the markings no less than 3.9" in height on two opposing sides near the proper shipping
name or near the placards?
Don Ladner
Dufour Petroleum LP
Safety Supervisor
Thanks,
Petal, Ms. 39465
P.O. Box 1184
Don Ladner
601-583-9991 Ext.238
9/15/2006
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