The Fertilizer Institute — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 JUL 2 9 2008 Ms. Pam Guffain Vice President, Member Services The Fertilizer Institute 820 First Street, N.E. Suite 430 Washington, D.C. 20002 Ref. No.: 08-0059 Dear Ms. Guffain: This responds to your letter regarding the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180) applicable to Anhydrous Ammonia shipped from Canada to the United States. Specifically, you ask if the placard required under Canada's Transportation of Dangerous Goods (TDG) Regulations is acceptable when shipping Anhydrous Ammonia from Canada into the United States by highway or rail. The answer is yes. Shipments of Anhydrous Ammonia prepared in accordance with the TDG Regulations are not required to be labeled or placarded with POISON INHALATION HAZARD or POISON GAS labels or placards (See !j 17 1.23(b)(l O)(iv)). Thus, a package containing "Anhydrous Ammonia" shipped to the United States from Canada by motor carrier or rail car may be labeled or placarded in accordance with the TDG Regulations. Special Provision "1 3", in !j 172.102, specifies that for "Anhydrous ammonia," the words "Inhalation Hazard" must be entered on each shipping paper in association with the shipping description, and each non-bulk package must be marked '"INHALATION HAZARD" in association with the proper shipping name and identification number. Bulk packages must be marked on two opposing sides with the words 'INHALATION HAZARD". The size of the marking on bulk packages must conform to $ 172.302(b). For your information, Amendment 6 of the TDG Regulations was published in the Canada Gazette, Part I, on September 30,2006. The new subsection 4.18(5) requires that one of the following placards must be displayed when UN1005, ANHYDROUS AMMONIA, is contained in a large means of containment: Until August 3 1,2008, the Class 2.2, Class 2.3 or the new Anhydrous Ammonia placard (see the Appendix to Part 4 of the TDG Regulations);#

Page 2After August 3 1,2008, the Class 2.3 placard or the new Anhydrous Ammonia placard; and On at least two sides, the words bbAnhydrous Ammonia, Inhalation Hazard" on a contrasting background in letters with a width of at least 6mrn and a height of at least 50 mm when the Anhydrous Ammonia placard is displayed on it. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, &,(3b - afl(j Susan Gorsky Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Enq rum Page 1 of 1 Drakeford, Carolyn cPHMSA> From: Gorsky, Susan <PHMSA> Sent: Thursday, February 28, 2008 1.38 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Canadian Reclassification I realize this is a bit unorthodox, but could you assign this for response? Her question relates to placarding requirements for shipments of anhydrous ammonia from Canada into the United States. Specifically, she wants to know if the placard required under Canada's Transport of Dangerous Goods regulations is acceptable when the shipment comes into the United States. Susan From: Pam Guffain [mailto:PGuffain@tfi.org] Sent: Wednesday, February 27, 2008 1:59 PM To: Gorsky, Susan <PHMSA> Subject: Canadian Reclassification Dear Susan, Great meeting today. Thanks. We will be back in touch with you all soon on this issue. As we talked, would you mind confirming in writing that our reciprocity is ok now that Canada has formally reclassified ammonia. It would help my members if they saw it in writing! Again, congratulations on your decision to retire! Pam Pam Guffain Vice President, Member Services The Fertilizer Institute 820 First Street, N.E., Suite 430 Washington, D. C. 20002 (202) 5 1 5-2704 - direct (202) 257-3043 - cell#