Veolia Environmental Services — Hazardous Materials Safety Interpretation

Page 1.S. Departme f Transportatio Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety MAY 15 2007 Ms. Jennifer Eberle Ref. No. 07-0074 Veolia Environmental Services Manager, Transportation Compliance Flanders, NJ 07836 One Eden Lane Dear Ms. Eberle: This responds to your April 10, 2007 letter requesting clarification on the use of the 49 CFR Parts 171-180). Specifically, you ask for confirmation that the DANGEROUS DANGEROUS placard under §172.504(b) of the Hazardous Material Regulations (HMR; placard is not required in your situation. gross weight of three Table 2 materials in non-bulk packages as follows: Class 8 and Class According to your letter, you have a truckload shipment of 3,300 pounds total aggregate 3 materials (500 pounds each) and Division 5.1 material (2,300 pounds) loaded at one loading facility. Section 172.504(b) authorizes the use of the DANGEROUS placard instead of the separate placards specified for the three hazardous materials in Table 2 for shipments of two or more categories of Table 2 materials in non-bulk packages that require different placards. Thus, the DANGEROUS placard is authorized for your mixed truckload shipment. However, when 1,000 kg (2,205 pounds) aggregate gross weight of more than one category of material is loaded at one loading facility, the placard specified in Table 2 for that category must be applied. The DANGEROUS placard is already authorized for use on the mixed truckload shipment. but, since the aggregate gross weight of the Division 5.1 material the 2.300 pounds of Division 5.1 material that was loaded at one loading facility. exceeds the 2,205 pound threshold, the OXIDIZER placard is now also required to cover truckload shipment to indicate the presence of both the Class 8 and Class 3 materials, as Therefore, both the DANGEROUS and OXIDIZER placards should be used for this mixed well as the Division 5.1 materials. I hope this answers your inquiry. Office of Hazardous Materials Standards 172.504(b) 070074#

Page 2Boothe @ VEOLIA 5172.504(6) April 10, 2007 17-0074 Office of Hazardous Materials Standards Mr. Edward T. Mazzullo, Director USDOT/PHMSA (PHH-10) 400 7th Street, SW Washington D.C. 20590-0001 Dear Mr. Mazzullo, Please accept this letter as a request for a formal interpretation from your office. Veolia §172.504(b). wishes to receive clarification related to the DANGEROUS placard exception found in It is our interpretation that a truckload shipment of non-bulk packages containing the flaring aggregate gross weights would be required to display only the OXIDIZER (5.1) Class 8 = 500 pounds Class 3 = 500 pounds Class 5.1 = 2300 pounds Is it correct to no longer consider the weight of a Table 2 material for which a specific determining the appliedity or the DANGEROUS prass weight of Table 2 materials wher TABLE 2 MATERIAL REQUIRED PLACARD Class 5.1 = 2300 pounds (>2,205 Ibs. loaded at one loading facility) OXIDIZER 5.1 Class 3 = Class 8 = 500 pounds Total = 1,000 pounds 500 pounds (Total aggregate weight of Table 2 materials is < 1,001 lbs.) NONE Your written response to this question is greatly appreciated. If you require any further information regarding this letter please contact me at 973-448-4209 o iennifer.eberle@veoliaes.com. Thank you, Jennifer Eberle Manager, Transportation Compliance the pore wore.c for 1 07936#