Fleet Safety Services, Inc — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 APR 0 1 2010 Mr. Gary LaBreck Fleet Safety Services, Inc l2 Harvard Street Worcester, MA 01609 Ref. No. 09-0120 Dear Mr. LaBreck: I This responds to your letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically, you ~sk whether a pickup truck towing a trailer is considered two separate transport vehicles for the purposes of placarding under the HMR. Your client intends to tr~sport less than 1 ,dp1 Ibs aggregate gross weight of non-toxic compressed gases in both the! pickup truck and t~e trailer where the total aggregate gross weight of cylinders in both cargo-¢arrying bodies exqeeds 1,001Ibs. I I As you are aware, § 171.8 of the HMR defines a transport vehicle as "a cargo-carryirlg vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or railcar used\ for the transportation of cargo by any mode. Each cargo-carrying body {trailer, rail car, etc'tiS a separate transport vehicle." Additionally, you are aware that placards are not require' on a transport vehicle which contains less than 454 kg (I,OOllbs) aggregate gross weight, f I hazardous materials covered by table 2 of paragraph ( e) under § 172.504. In the scen~rio you describe, the pick-up truck and trailer are two separate transport vehicles each carrying less than 454 kg (l,OOllbs) of eligible hazardous materials. Therefore, neither the pick-up truck nor the trailer is required to be placarded in highway transportation. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2. Drakeford, Carolyn <PHMSA> .. From: INFOCNTR <PHMSA> . Sent: Wednesday, May 13, 2009 3:34 PM To: Drakeford, Carolyn :<PHMSA> I Subject: FW: Hazmat Information Center Feedback: General Information, RegU~lations, al"ld Definitions (Sections 171 1 &ndash; 171.26) ~ · -----Original Message----From: PHMSA-Feedback [mailto:PHMSA-Feedback] ~ r. ' tS 1112 .6D'1 . ~'1.1 ~ ,) Sent: Wednesday, May 13, 2009 3:06 PM ~nl-hoV\~ 1/ g1f.!a~d'd To: PHMSA HM InfoCenter; PHMSA Webmaster ect: Hazmat Information Center feedback: General Information, Regu1atio~s, and(J it Definitions (Sections 171.1 &ndash; 171.26) REQUEST FOR A INTERPRETATION LETTER §171.8 Definitions and abbreviation~. Transport vehicle means a vehicle such as an automobile, van. tractor, truck, semitrailer, tank car or used for the transportation of car¢o by any mode. Each cargo-carrying body (trailer, car, etc.) is a transport vehicle. §172.504 General placarding requirements. (c) (1) A transport vehicle or freight container which less than 45 kg (1001 pounds) aggregate gross of hazardous materials by Table 2 of paragraph (e) of this section; or Could I please receive an interpretation letter on the I have a client that does environmental testing. They which as a GVWR of 10,001 lbs or more. They also tow a trailer more. They haul cylinders of compressed the trailer. They ~nder 454kg (1001 pounds). Per 172.504(c) (1) it not meet the plac~rding requiremen~s. ! I Under 171.8 it states that the and trailer are a e transport cleo The question for the interpretation letter is, can they cartry cylinders in vehicle as long as each vehicle has a weight under 454 (~001 pounds)? Name: Gary LaBreck Organization: Fleet Services lIne. Email: glabreck@fleet-safety.com Address: 12 Harvard Street : Worcester Zip Code: 01609 Phone: 508-868-1380 FAX: 508-831-7611 1#