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Page 1of Transportation U.S. Department Wash ngton, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Mr. Byver Daniell Ref. No.: 07-0019 4310 National Guard Drive Hy Yield Bromine Inc. Plant City, FL 33563-1112 Dear Mr. Daniell: 26, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 This is in response to your telephone conversation with a member of my staff and January transport vehicle carrying 31,500 pounds of UN 1581, Chloropicrin and methyl bromide CFR Parts 171-180) applicable to placarding and marking. Your scenario involves a mixtures, Division 2.3, in non-bulk packages. The transport vehicle displays a POISON GAS placard, containing the identification number "1581", on each side and each end. HAZARD." You ask if the transport vehicle is required to be marked with the words "INHALATION The answer is no. Each non-bulk package must be marked "Inhalation Hazard" in transport vehicle containing large quantities of a material poisonous by inhalation in non- association with the required label and shipping name as required by § 172.313(a). A bulk packages must be marked, on each side and each end as specified in § 172.332 or paragraph (c) of § 172.313. The identification number may be displayed on the POISON 3112.336, with the identification number specified for the hazardous material. See displayed on the placard, there is no requirement to display the "INHALATION GAS placard as permitted by §§ 172.332 and 172.334. When the identification number is HAZARD" wording on the transport vehicle or across the center of an additional POISON GAS placard. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, i Hattie Mitchell Office of Hazardous Materials, Standards Chief, Regulatory Review and Reinvention 112.313(a) 172.336 172.519 070019 172.540#
Page 2FROM HY YIELD BROMINE (FRI) JAN 2007 8:28/ST. 8:1E/No. 6802289746 P SaHerthwaite January 26,2007 $172.313 $172.519 Hy Yield Bromine, Inc. 12. 34 4310 National Guard Dr. lacardly. Plant City, Fl. 33563-1112 07-0019 Director, Office of Hazardous Material Standards Mr. Edward Mazzullo 400 7th Street S.W. USDOT / PHMSA ( PHH-10 ) Washington, DC. 20590-0001 Dear Sir; conversation yesterday ( 1-25-07 ) with Cameron Satterthwaite, writing this letter in response to a telephone of your office. materials in van trailers and on flatbeds. We are transporting Table 1 ( Packing group I Zone B ) Quantities up to 31,500 pounds. Example: UN1581 | Methyl Bromide and Chloropicrin mixes : These are poison inhalation hazard materials placard Is it necessary to display as well as the ( 1581) placard INHALATION HAZARD eref Byver Daniell 2 Operations Manager 1-813-754-8095 Fax 1-813-752-4244 Office 1581 2#
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