{"operation":"document","citation":"08-0059","title":"The Fertilizer Institute — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-07-29","effective_on":null,"summary":"08-0059 response to The Fertilizer Institute concerning 171.23, 172.102, 172.302.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0059.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0059.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0059","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080059.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nJUL 2 9 2008\nMs. Pam Guffain\nVice President, Member Services\nThe Fertilizer Institute\n820 First Street, N.E. Suite 430\nWashington, D.C. 20002\nRef. No.: 08-0059\nDear Ms. Guffain:\nThis responds to your letter regarding the placarding requirements under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171 - 180) applicable to Anhydrous Ammonia\nshipped from Canada to the United States. Specifically, you ask if the placard required under\nCanada's Transportation of Dangerous Goods (TDG) Regulations is acceptable when\nshipping Anhydrous Ammonia from Canada into the United States by highway or rail.\nThe answer is yes. Shipments of Anhydrous Ammonia prepared in accordance with the TDG\nRegulations are not required to be labeled or placarded with POISON INHALATION\nHAZARD or POISON GAS labels or placards (See !j 17 1.23(b)(l O)(iv)). Thus, a package\ncontaining \"Anhydrous Ammonia\" shipped to the United States from Canada by motor\ncarrier or rail car may be labeled or placarded in accordance with the TDG Regulations.\nSpecial Provision \"1 3\", in !j 172.102, specifies that for \"Anhydrous ammonia,\" the words\n\"Inhalation Hazard\" must be entered on each shipping paper in association with the shipping\ndescription, and each non-bulk package must be marked '\"INHALATION HAZARD\" in\nassociation with the proper shipping name and identification number. Bulk packages must be\nmarked on two opposing sides with the words 'INHALATION HAZARD\". The size of the\nmarking on bulk packages must conform to $ 172.302(b).\nFor your information, Amendment 6 of the TDG Regulations was published in the Canada\nGazette, Part I, on September 30,2006. The new subsection 4.18(5) requires that one of the\nfollowing placards must be displayed when UN1005, ANHYDROUS AMMONIA, is\ncontained in a large means of containment:\nUntil August 3 1,2008, the Class 2.2, Class 2.3 or the new Anhydrous Ammonia\nplacard (see the Appendix to Part 4 of the TDG Regulations);\n\n<<<PAGE 2>>>\n\nAfter August 3 1,2008, the Class 2.3 placard or the new Anhydrous Ammonia\nplacard; and\nOn at least two sides, the words bbAnhydrous Ammonia, Inhalation Hazard\" on a\ncontrasting background in letters with a width of at least 6mrn and a height of at least\n50 mm when the Anhydrous Ammonia placard is displayed on it.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\n&,(3b - afl(j\nSusan Gorsky\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nEnq rum Page 1 of 1\nDrakeford, Carolyn cPHMSA>\nFrom: Gorsky, Susan <PHMSA>\nSent: Thursday, February 28, 2008 1.38 PM\nTo: Drakeford, Carolyn <PHMSA>\nSubject: FW: Canadian Reclassification\nI realize this is a bit unorthodox, but could you assign this for response? Her question relates to placarding\nrequirements for shipments of anhydrous ammonia from Canada into the United States. Specifically, she wants\nto know if the placard required under Canada's Transport of Dangerous Goods regulations is acceptable when\nthe shipment comes into the United States.\nSusan\nFrom: Pam Guffain [mailto:PGuffain@tfi.org]\nSent: Wednesday, February 27, 2008 1:59 PM\nTo: Gorsky, Susan <PHMSA>\nSubject: Canadian Reclassification\nDear Susan,\nGreat meeting today. Thanks. We will be back in touch with you all soon on this issue.\nAs we talked, would you mind confirming in writing that our reciprocity is ok now that Canada has formally\nreclassified ammonia. It would help my members if they saw it in writing!\nAgain, congratulations on your decision to retire!\nPam\nPam Guffain\nVice President, Member Services\nThe Fertilizer Institute\n820 First Street, N.E., Suite 430\nWashington, D. C. 20002\n(202) 5 1 5-2704 - direct\n(202) 257-3043 - cell","truncated":false,"body_characters":3863}