Pipe Recovery Systems, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Mr. Michel Charnmas General Manager Pipe Recovery Systems Inc. 1462 Brittmoore Road Houston, Texas 77043 1200 New Jersey Avenue. SE Washington, D.C. 20590 Ref. No.: 07-0230 Dear Mr. Chamrnas: This responds to your December 4,2007 letter requesting clarification of the placarding provisions specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). Your scenarios involve the application of $$ 172.504 and 172.505. Your questions are paraphrased and answered'below . Q 1. What placards are required on a freight trailer transporting less than 1,000 pounds of non- bulk packages that contain a material, UN1746, Bromine Trifluoride, 5.1 (6.1) (8), PG I, Poison-Inhalation Hazard Zone B? A1 . Under the HMR, OXIDIZER placards for the primary hazard and POISON INHALATION HAZARD placards are required, as prescribed by §$ 172.504(e) Table 2, and 172.505(a) respectively. The 454 kg (1,OO 1 pounds) exception in $ 172.504(c) does not apply to a material that is required to display a subsidiary POISON INHALATION HAZARD placard in accordance with 8 172.505(a). As specified in $ 172.505(d), display of the CORROSIVE placard for the subsidiary hazard is permissible, but not required. 42. What placards are required on the freight trailer specified above in Q1 if a box of Division 1.4G Igniters, weighing less than 5 pounds, is added? A2. See A1 . No additional placards are required. The Division 1.4G material is eligible for the $ 172.504(c) placarding exception even when transported on the same transport vehicle with non-bulk packages of a Division 5.1, Poison-Inhalation Hazard material subject to $ 172.505. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2December 4,2007 Mr. Edward T. WlazzuHo Director, Office of Hazardous Materials Standards W.S. DQTlPHMfjA (PHW-10) 1200 New Jersey Avenue, SE East Building, 2" Floor Washington, DC 20590 RE: Request far Letter of Interpretation for 49 CFR 172.504 and 172.505 Dear Mr. Mazzullo: We have received varying interpretations of the placarding requirements listed under 49CFR 172.504 and 172.505, Your advice IS now requested to clarify the' requirements so that we can ensure all regulations are being followed accordingly. Our questions are as follows: Q I . If I am shipping a material, UN 1746 Bromine Trifluoride (which is primary class 5.1 oxidizer, subsidiary risk 6.1 (poisonous by inhalation), subsidiary risk 8 corrosive) and the quantity is under 1001 Ibs, what placards, if any, are required on a fre~ght vehtcle7 Q2. If I am shipping the Bromine Trifluoride along with a box of class 1.4G Igniters (weigh~ng less than 5 Ibs), what are my placarding options? General Manager Pipe Recovery Systems, Inc.#