Hazmat, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE Washington, DC 20590 Mr. Paul J. Dambek Hazmat, Inc. 12 Kimball Hill Road Hudson, NH 0305 1-391 5 Ref. No.: 09-0201 Dear Mr. Dambek: This responds to your August 14,2009 letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80). Your questions are paraphrased and answered below. Ql. A shipper offers for transportation two cylinders of Chlorine, UN1017,2.3 (5.1, 8). The gross weight of this shipment is 800 pounds. Must the vehicle be placarded with the poison gas, oxidizer, and corrosive placards? Al. No. The required placard for "UN 10 17, Chlorine, 2.3" is the POISON GAS placard. See 5 172.504(e), Table 1. Placarding for the subsidiary 5.1 and 8 hazards is not required, but is permissible as specified in 5 172.505. The HMR do not specify how to display the primary and subsidiary placards in relation to each other; however, each placard must be clearly visible from the direction it faces. Q2. A shipper offers for transportation two cylinders containing residual amounts of Chlorine, UN1017,2.3 (5.1,8). Is the shipment required to be placarded? A2. Yes. As specified in 9 173.29, empty packagings containing the residue of a hazardous material must be offered and transported in the same manner as when they previously contained a greater quantity of the hazardous material unless the packagings are sufficiently cleaned of residue and purged of vapors to remove any potential hazard, or are refilled with a material that is not subject to the HMR. Q3. A shipper offers for transportation a drum of Chlorosulfonic acid, UN 1754, 8 (6. I), PG I for transportation by highway. The gross weight of the material is 450 pounds. Is the shipment required to be placarded? A3. Yes. In accordance with 9 172.505(a), a poisonous material subject to the "Poison Inhalation Hazard" shipping description requirements in 9 172.203(m) must be placarded with a POISON INHALATION HAZARD or POISON GAS placard. Chlorosulfonic acid meets#

Page 2-2- October 1, 2009 the definition for a material that is poisonous by inhalation (see Special Provision 2 as indicated in Column 7 for the entry for Chlorosulfonic acid in the Hazardous Materials Table in tj 172.1 01) and, therefore, is subject to the shipping description requirements in 172.203(m) and the placarding requirements in 5 172.505(a). I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, &Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3HAZMATEAM, ZNC. 12 Kimball Hill Rd. Hudson, NH 0305 1-391 5 Telephone (603) 882- 1 1 12 Fax (603) 882-65 12 E-Mail: hazmateam@earthlink.net www.hazmatearn.com IATA DANGEROUS GOODS ACCREDITED SCHOOL August 14,2009 Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration ATTN: PHH-10 U.S. Department of Transportation 466 yth Srree~ Washington, D.C. 20590 Dear Sirs: I have a question concerning the applicability 49 CFR 172.505, subsidiary placarding. Consider the following scenarios: #1) A shipper offers for transportation two cylinders of chlorine gas (UN 101 7, Chlorine, 2.3 (5.1, 8)) on one truck. The aggregate gross weight of this shipment is 800 pounds. Must the vehicle be placarded with the poison gas AND oxidizer & corrosive placards? #2) Consider scenario #1 above, but the cylinders only have residual amounts of gas in the cylinders. Which placards must be affixed to the truck? #3) One drum of UN 1754, Chlorosulfonic acid, 8 (6.1), PG I is offered for transportation on a truck. Chlorosulfonic acid is a PIH, Zone B chemical. The gross weight of the drum is 450 pounds. must be affixed to the truck? Which placards Your assistance is greatly appreciated. Sincerely, Paul J. ~ a m b e k#