{"operation":"document","citation":"07-0171","title":"4th ID-Fort Carson G3/IMT — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-10-16","effective_on":null,"summary":"07-0171 response to 4th ID-Fort Carson G3/IMT concerning 172.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0171.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0171.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0171","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070171.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nArmans herdous\nOCT\n16 2007\n4*h ID-Fort Carson\nMr. Len Hammond\nRef. No. 07-0171\nG3/IMT\n1675 Long Street\nFort Carson, CO 80913-4138\nBldg. 1117, Room 207\nDear Mr. Hammond:\nrequirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nThis responds to your August 31, 2007 letter requesting clarification of the placarding\nSpecifically, you ask for clarification on the use of the DANGEROUS placard under\n§172.504(b) for your scenarios. Your questions are paraphrased and answered as follows:\nQ1: A transport vehicle or freight container is loaded with 1,200 kg of Class 3 flammable\nliquids; 200 kg Division 6.1 poison material (not an inhalation hazard); and 300 kg Class &\ncorrosive material. There are no subsidiary hazard classes. May we apply the Class 3\nFLAMMABLE LIQUID placard for Item 1 and the DANGEROUS placard for Items 2 and\nAl: Yes. Placards are required because the aggregate gross weight (1,700 kg) of the Class 3,\n§172.504(b), the DANGEROUS placard may be substituted for the POISON AND\nDivision 6.1, and Class 8 hazardous materials exceeds 454 kg (1,001 Ib). As provided in\nCORROSIVE placards. The FLAMMABLE LIQUID placard must be used for the Class 3\nmaterial since it exceeds 1,000 kg (2,205 Ib) loaded at one facility.\nQ2: A transport vehicle or freight container is loaded with 500 kg Division 6.1 poison\nmaterial. May we apply only the DANGEROUS placard?\nmaterial (not an inhalation hazard); 200 kg Class 3 flammable liquid; and 100 kg Class 8\nA2: Yes. The DANGEROUS placard may be used to cover all three Table 2 hazardous\nmaterials.\nQ3: A transport vehicle or freight container is loaded with 50 kg Division 6.1 poison\norrosive material. Are placards required'\nnaterial (not an inhalation hazard); 200 kg Class 3 flammable liquid; and 100 kg Class\n17250466)\n070171\n\n<<<PAGE 2>>>\n\n(1,001 lb), no placards are required.\nA3: No. Since the aggregate gross weight of all three Table 2 materials is less than 454 kg\nQ4: A transport vehicle or freight container is loaded with 1,200 (exceeds 2,205 lb) Class 3\nClass 3 FLAMMABLE LIQUID the only placard required?\nflammable liquid; and 200 kg Division 6.1 poison material (not an inhalation hazard). Is the\nA4: No. The FLAMMABLE LIQUID placard is required because 1,000 kg of Class 3\nmaterial has been loaded at one facility. However, because the entire aggregate gross weight\nlacard or POISON placard must be used for the Division 6.1 material\nof hazardous materials on the transport vehicle exceeds 454 kg, either the DANGEROUS\nI hope this answers your inquiry.\nSincerely\nChief, Standards Development\nOffice of Hazardous Materials Standards\n2\n\n<<<PAGE 3>>>\n\nBoothe\n5172.504(6)\n•\nMEMORANDUM\nPlacarding\nDATE:\n31 AUGUST 2007\n07-0172\nFROM:\nLEN HAMMOND\nTo:\nSHANE KELLEY\nGLENN FOSTER\nOFFICE OF HAZARDOUS MATERIALS SAFETY, PHH-70\nCANDACE SIMON\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n400 7TH STREET, S.W. ROOM 8421\nU.S. DEPARTMENT OF TRANSPORTATION\nWASHINGTON, D.C. 20590-0001\nSUBJ:\nREQUEST FOR CLARIFICATION ON PLACARDING EXCEPTIONS\nI am writing to request clarification and a letter of interpretation of the exceptions\nfor placarding in accordance with 49 CFR §172.504.\n§172.504(a) states that \"...each freight container, unit load device, transport vehicle\nr rail containing any quantity of a hazardous material must be placarded on eac\nide and each end with the type of placards specified in Tables 1 and 2 of thi\nsection.\" As this is the basic rule and can only be deviated from with those\nexceptions as listed in subsequent exceptions, it is understood that only those items\nmeeting one or more of the exceptions listed may be exempted from mandatory\nplacarding.\nThose exceptions include:\n\"Dangerous\" placarding for those items in Table 2 for which a placard is required\n§172.504(b) Dangerous Placard. This exception provides for a summarizing\n[i.e. does not meet the exception of §172.504(c)]. However as I read this section, this\nexception does not apply to those items with an aggregate gross weight of more than\n1000 kg.\nI would like to offer several scenarios for your clarification in the application of the\nDangerous Placard exception.\nScenario # 1:\nA transport vehicle/container/unit load device is loaded with the aggregate gross\nweights of the following Hazard Classes.\nItem 1: Class 3, Flammable liquids; 1,200 kg\nItem 2: Class 6.1, Toxic material (not an inhalation hazard), 200 kg\nItem 3: Class 8, Corrosive liquids, 300 kg\n\n<<<PAGE 4>>>\n\nAll items are in Table 2 and are qualified for the Dangerous Placard Exception\nItem 1 is pretty straight forward as it is greater than 1,000 kg and does not meet the\nexception as it is addressed in §172.504(b) under the rule for items greater than 100\nkg and must be placarded for.\nItems 2 & 3 do not meet the greater than 1,000 kg and are subject to the Dangerous\nPlacard exception.\nTherefore in Scenario # 1 the two placards which are to be applied are the\nFlammable Liquid, Class 3 placard for Item 1 and the Dangerous Placard for Items\n2 & 3. (Item 1 is not to be considered in the computation of aggregate gross weight\nfor applying this exception since is greater than 1,000 kg and has already been\nplacarded for).\nScenario # 2\nItem 1: Class 6.1, Toxic material (not an inhalation hazard); 500 kg\nItem 2: Class 3, Flammable liquid; 200 kg\nItem 3: Class 8, Corrosive solids, 100 kg\nAll items are Table 2 items but since none are greater than 1,000 kg, they are all\nthree items is greater than 454 kg therefore the Dangerous Placard can be used to\neligible for the Dangerous Placard exception. The total aggregate gross weight of all\nsummarize all three items.\nPlacard required for Scenario #2 is only the Dangerous Placard for all three items.\nScenario # 3\nItem 1: Class 6.1, Toxic material (not an inhalation hazard); 50 kg\nItem 3: Class 8, Corrosive solids, 100 kg\nItem 2: Class 3, Flammable liquid; 200 kg\nAll items are Table 2 items but since none are greater than 1,000 kg, they are all\neligible for the Dangerous Placard exception. The total aggregate gross weight of all\nthree items is less than 454 kg therefore no placard is required under §172.504(c)\nwhich states \"... except for bulk packagings and subject to §172.505 (subsidiary\nhazards requiring placarding), when hazardous materials covered by Table 2 of this\nsection are transported by highway or rail, placards are not required...\" on\ntransport vehicles/containers/rail cars which contains less than 454 kg aggregate\ngross weight of Table 2 hazardous materials.\nPlacards Required: None\n\n<<<PAGE 5>>>\n\nScenario # 4\nItem 1: Class 3, Flammable liquids; 1,200 kg\nItem 2: Class 6.1, Toxic material (not an inhalation hazard), 200 kg\nItem 1 is pretty straight forward as it is greater than 1000 kg and does not meet the\nexception as it is addressed in §172.504(b) under the rule for items greater than\n1,000 kg and must be placarded for.\nItem 2 does not meet the greater than 1,000 kg and may subject to the Dangerous\nexception of §172.504(c) and does not have to be placarded for.\nPlacard exception. However since the item is less than 454 kg it falls under the\nPlacards Required: Flammable Liquid 3 only.\nThe reason I ask for this clarification is that there are continuous questions as to\nfor the Dangerous Placard exception. I think that only those Table 2 items which are\nwhether a Table 2 item greater than 1,000 kg is to be considered in the computation\nless than 1,000 kg are to be considered based on the statement in §172.504(b)\n\"However, when 1,000 kg aggregate gross weight or more of one category of\ndevice, transport vehicle, or tail care, the placard specified in Table 2 of paragraph\nmaterial is loaded therein at one loading facility on a freight container, unit load\n(e) of this section for that category must be applied.\" This is as demonstrated in\nScenario # 1.\nI think the misunderstanding occurs because of he wording of §172.504(b) is often\nmisinterpreted to require the inclusion of the aggregate gross weights of all Table 2\nitems, even those already placarded for under the greater than 1,000 kg rule when\ncomputing the aggregate gross weight for the Dangerous exception. As I read this\nsection, it seems to exclude those Table 2 items already placarded for under the\ngreater than 1,000 kg rule. Maybe the more correct statement would be to define the\nDangerous Placard rule to those items in Table 2 not already placarded for under\nthe greater than 1,000 kg rule. This question is most often raised in response to a\nscenario such as in # 4 where the gross weight of the one Table 2 item greater than\n1,000 kg is included in the Dangerous Placard exception computation. This would\nresult in that item being placarded for twice, with its own specific placard and again\nunder the summarization of hazards eligible for the Dangerous Placard rule.\n\n<<<PAGE 6>>>\n\n:\nCould you please review these scenarios and provide a clarification of the\nThat your no lethe koading ale? pervence rised thie a ra consensu in hopes\nThank you for your assistance in insuring that all instruction is based on the same\napplication of rule.\nLen Hammond\nLEN HAMMOND\n4'* ID - FORT CARSON\nG3/IMT ATTN: LEN HAMMOND\n1675 LONG STREET\nFORT CARSON, CO 80913-4138\nBLDG. 1117, RoOM 207\nlen.hammond@us.army.mil","truncated":false,"body_characters":9312}