North Carolina State Highway Patrol — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration APR - 1 2010 Lt. D. R. Shackelford Assistant MCSAP Administrator North Carolina State Highway Patrol 4702 Mail Service Center Raleigh, NC 27699-4701 Ref. No. 10-0046 Dear Lt. Shackelford: This responds to your November 13,2009 email concerning the requirement of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to secure packages in a motor vehicle. Specifically, you ask about securing propane cylinders in accordance with § 177.834. According to your email, the propane cylinders are placed in recessed trays so that the base of each cylinder sits two inches below the horizontal edge ofthe tray. The trays may be stacked; however, whether stacked or unstacked, no tray or other device is placed on top of the cylinders. You provide pictures illustrating this method of securing the cylinders. Additionally, in a telephone conversation with a member of my staff, you noted that these trays are placed in a closed freight vehicle known a "mickey body" truck. It is your understanding from visual inspections that this method secures the cylinders against shifting, including overturning and ejection from the motor vehicle, under conditions normally incident to transportation and that the likelihood of damage to the cylinder valves is minimal. You ask if this method of securing the cylinders complies with § 177.834(a) or whether a locking ring or other device designed to secure the topmost cylinders is also needed. Based on the information provided, it is the opinion of this Office that this method of securing the cylinders would achieve compliance with the general requirements of § 177.834(a) as well as the loading requirements specific to transport of Class 2 gases in § 177.840(a)(1). Therefore, so long as there is no shifting or overturning of the cylinders during normal transportation conditions, a locking ring or other method of securing the topmost cylinders is not required. I hope this information is helpful. If you have further questions, please contact this office. Sinc;J.iY , CharieS~ Chief, Standards Development ce of Hazardous Materials Standards#

Page 2Drakeford, Carol n From: Sent: To: Subject: Shackelford, Douglas R. [drshackelford@NCSHP.ORG] Friday, March 05, 20109:57 AM INFOCNTR (PHMSA) FW: Interpretation Completed via phone by RB on 3/5 @ 1020 am Dear Sir: In November 2009, I sent the below information in for an Interpretation. From conversation with folks that attended COMED it has been indicated the absence of the locking ring would not be required therefore resulting in a violation 177.834. I have not heard back yet of the official interpretation from your Section. Please advise. Lieutenant Shackelford From: Shackelford, Douglas R. Sent: Friday, l\Jovember 13, 2009 10:55 AM To: 'infocntr@dot.gov' Subject: Interpretation Dear Sir: I have a question in reference to 49CFR 177.834 when transporting 20lb propane gas cylinders. All the cylinders are stacked in approved recessed trays so the base of the cylinders about two inches deep. The next tray is placed on top of that row and so on, however the final tray or top tray of cylinders have no devise on the top but are still recessed about one and one half inches inside the tray. q I have pictures that can be sent or should I provide this question to another section of PHMSA? Question: Thanks Is a locking ring required to encompass the top tray or will it comply with 177.834 without the ring? LieutenantD. :Jl. Sliacke!/ortf North Carolina State Highway Patrol Motor Carrier Enforcement Section Assistant MCSAP Administrator Raleigh, North Carolina Office: (919) 715-8683 FAX (919) 715-8196 1#

Page 3Drakeford, Carolyn (PHMSA) From: Shackelford, Douglas R. [drshackelford@NCSHP.ORG] Sent: Friday, March 05, 2010 10:44 AM To: INFOCNTR (PHMSA) Subject: FW: Lexmark Scan Attachment Attachments: document20 10-03-05-103004. pdf Sir: Please see the attached documents. The first image is a picture of a locking ring designed by a private vender for use on the top rack of cylinders being transported however the question remains. Is it required to be utilized on the top rack when the cylinders are recessed in the bottom tray about two inches as indicated in the other images to be in compliance with l77.834a? Thanks Lieutenant Shackelford -----Original Message----From: Sent: FridaYJ March eS J 2ele le:3e AM To: ShackelfordJ Douglas R. Subject: Lexmark Scan Attachment DO NOT REPLY TO THIS EMAIL. 1#

Page 410/11 - 38.50 - PAGE 1.00 - 12.59 - 13.25 tal Ф8.94 12X R.25 TYP 6.00 Is this required to be utilized on top culinders fo 8.00- compliance of TRANAN 49.50 177.8340. 12.50 NOTE: THIS RING IS TO BE USED IN CONJUNCTION WITH TS4253 TRAYS 5173390459 IF PRINTED, TO BE CONSIDERED AN UNCONTROLLED DOCUMENT UNLESS OTHERWEE SPECIFIED: HAME DAE TRAVEL STAR PRODUCTS TOLERANCES: DIVENIONS AREIN INCHES DRAWN REZ 5/21/0S 8080X8S3, B05K84, IN. 46527 6746330467 ANSULAR: 4f-1 CHECKRY TITLE: TWO PLACE DECIAL +). 043° - ONE PLACE DECIMAL +!-.125 ENG APPR. 17:37 THREE PLACE DECIAL +1-315 JARG APPR TSCPCYL-R12 CYLINDER RING FROPRIETARY AND CONFIDENTIAL CAVIES 7Y00 TOOL HATE IOLERANCING PER. INTERFRET GEOMERIC QA DRAWING IS THE SOLE PROPERTY OF THE INFORMATION CONTAINED IN THIS IOC. MATERIAL • MATERAL STARING ICINES COMMENTS: PRASH .187" BLACK PE SIZE DWG. NO. REV TRAVEL STAR PRODUCTS ANY 89/89/2009 WITHOUT THE WRITTEN PERMISSION OF REPRODUCTION IN PART OR AS WHOLE TOONE SMOOTH - SMOOTH A TSCPCYL-R12 TRAVEL STAR PRODUCTS IS PROHIBITED. DO NOT SCALE DRAWING SCALE: 1:16 WEIGHT: SHEET 1 OF 1 5#

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