The Fertilizer Institute — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Ave. SE Pipeline and Hazardous of Transportation Washington DC 20590 Materials Safety Administration JUN 2 7 2007 Ms. Pam Guffain Ref. No. 07-0120 The Fertilizer Institute Vice President, Member Services 820 First Street, N.E., Suite 430 Washington, D.C. 20002 Dear Ms. Guffain: This is in response to your May 24, 2007 e-mail concerning the placarding requirements for the highway transportation of bulk packagings containing more than 5000 pounds of UN3082, III, RQ) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- Ammonium chloride, liquid (Environmentally hazardous substance, liquid, n.o.s., 9, required to be displayed on a transport vehicle containing a Class 9 material. However, a As provided by § 172.504(f)(9), when transported domestically a CLASS 9 placard is not bulk packaging containing a Class 9 material must be marked with the appropriate identification number displayed either on a CLASS 9 placard, an orange panel, or a white square-on-point display configuration. (See §§ 172.302 and 172.332). office. I hope this satisfies your request. If you have additional questions, please contact this Sincerely. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 1722504419) 070120#

Page 2Mitchell Page 1 of 1 3172: 504015) Drakeford, Carolyn <PHMSA> Applicabli From: Mitchell. Hattie <PHMSA> 07-0120 Sent: Tuesday, June 19, 2007 4:00 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Interpretation - the Fertilizer Institute Thanks. Carolyn, please log in to me. From: Pam Guffain [mailto:PGuffain@tfi.org] To: Mitchell, Hattie < PHMSA> Sent: Thursday, May 24, 2007 8:34 AM Subject: Interpretation Dear Hattie, I hope this finds you well. It has been awhile since we have communicated. I have had a conversation with the hazmat info office regarding an issue I am trying to resolve for one of our members and | just want to confirm that I am understanding this correctly. a hazardous substance in the DOT tables, but is not a hazardous material in 172.101. They transport in more than Our member transports in bulk, domestically by land, ammonium chloride liquid. Ammonium chloride is listed as the RQ of 5,000 Ibs. Lizmay endorstandint. the thy reburemen as understand fis to have ted notares the dry as UN to have a which is the identification number for environmentally hazardous substances, liquid, n.o.s. today to see the new "digs" and visit with Charlie Hochman. Thanks for your attention Hattie. I assume you are in your new building along with the others! I am coming over Pam Vice President, Member Services 820 First Street, N.E., Suite 430 The Fertilizer Institute 202-515-2704 (direct) Washington, D.C. 20002 202-257-3043 (cell) 202-962-0577 (fax) 6/19/2007#