Corrigan Propane — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE Washington, DC 20590 OCT 7 0" 2008 Mr. Bob Finn Corrigan Propane 775 N Second Brighton, MI 48 1 16 Ref. No.: 08-024 1 Dear Mr. Finn: This responds to your letter requesting clarification of the requirements regarding the transportation of propane cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically, you ask if the HMR allow propane cylinders to be transported in a fully enclosed trailer that is separate from the cab of the truck. Propane cylinders may be transported in a fully enclosed trailer. In general, cylinders must be manufactured and maintained in accordance with the HMR. In addition, the cylinders must meet the requirements for transporting Class 2 materials and the segregation requirements for highway transportation found in 55 177.834 and 177.840, respectively. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Huiil~e Heating * Corrstructiori Heat Propalre Disper~sis~y SPdtiuns arid Cyli~ider Excharrye Service 9-26-08 Department of Transportation Washington D.C. infocntr Re: Clarification To whom it may concern, I want to transport propane D.O.T. cylinders in enclosed trailers which are separate from the cab of the truck. Does this comply with the D.O.T. Hazmat requirements? I see "CFR 49 177.840 (1)" states that the cylinders containing Class 2 gases must be securely restrained in an upright or horizontal position (with pressure relief device in communication with the vapor space of the cylinder). Is there any code that states that these cylinders must be in open body trailers? Thanks for your help. Respecthlly, Bob Finn: Corrigan Propane bob~,corri~anoil.com PDF created with pdfFactory trial version www.pdffactorv.com#