Minnesota Department of Transportation — 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 OCT 28 2010 Mr. Michael Ritchie Hazardous Materials Specialist Minnesota Department ofTransportation Commercial Vehicle Operations Section 395 John Ireland Boulevard St. Paul, MN 55155 Ref. No.: 10-0126 Dear Mr. Ritchie: This responds to your letter regarding placarding and marking ofcargo tank motor vehicles in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked whether the required placards and markings, including the proper shipping name or common name and the INHALATION HAZARD marking, must be displayed directly on the cargo tank, or may the markings and placards be displayed on the "vehicle equipment boxes" or other appurtenances, as shown in the enclosed photographs of cargo tank motor vehicles in Liquefied Petroleum Gas (LPG) and Anhydrous Ammonia service, as long as the placards and markings are clearly visible. A cargo tank meets the definition of a bulk packaging and must be placarded on each side and each end. Section 172.516 states that each placard on a motor vehicle must be readily visible from the direction it faces except from the direction of another transport vehicle to which the motor vehicle is coupled. Generally, placards on the sides and ends ofthe cargo-carrying portion of a vehicle's cargo body satisfy requirements for placarding the sides and ends, as long as they are readily visible and not obscured by appurtenances in the direction they face. It is the opinion of this Office that a cargo tank motor vehicle placarded and marked with an identification number display, including the proper shipping name or common name and the INHALATION HAZARD marking, as depicted in your photographs, complies with the requirements in § 172.516 for visibility and display. I hope this information is helpful. Ifwe can be of further assistance, please contact us. Sincerely. ~ Ben~ Acting Chief, Standards Development Office ofHazardous Materials Standards#

Page 2Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations 395 John Ireland Blvd. St. Paul, MN 55155-1899 tnsrum ~ fl2. ·31 3 %Jll.· 328 June 7, 2010 <!3172-.5a4Charles E. Betts Chief, Standards Development M o..rlLl'Y>j IPIQCQrdll'lJ Office ofHazardous Material Standards JO-Of:lCo USDOTIPHMSA 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Placarding and marking of cargo tank motor vehicles Dear Mr. Betts, The Federal hazardous material regulations require placarding and marking ofboth bulk hazrnat packages and vehicles transporting hazardous materials. 49 CFR 172.504 requires placarding of each bulk packaging and transport vehicle, unless excepted. Section 172.514 requires each person offering a bulk packaging containing hazardous material to affix the placards specified for that material to the bulk packaging. Section 172.328 requires cargo tanks transporting Class 2 compressed gases to display the proper shipping name or common name ofthe material, and its ID number. Section 172.313 requires bulk packaging containing materials poisonous by inhalation to be marked INHALATION HAZARD on two opposing sides. Enclosed are photographs oftwo cargo tank motor vehicles. One is in propane service, the other in anhydrous ammonia service. Both display placards and markings on the equipment boxes attached to the vehicles, not on the bulk packaging itself. The placards and markings are clearly visible from the direction they face. Question: On a cargo tank motor vehicle in LPG or anhydrous ammonia service, must the required placarding and marking be displayed on the bulk packaging (the cargo tank) or may the required placards and marks, including the shipping name and the INHALATION HAZARD marking, when appropriate, be displayed on vehicle equipment boxes or other appurtenances, as long as those marks and placards are clearly visible? Michael Ritchie Hazardous Materials Specialist Minnesota Department of Transportation Commercial Vehicle Operations Section 395 John Ireland Boulevard St. Paul, MN 55155 (651) 366-3697 An equal opportunity employer#

Page 3PROPANE LANCENEAKES NOT Ph: 346-3500 Perham, MN Co-op Creamery Division of Perham Cenex Petroleum#

Page 41.888-550-SAFE ENETY 8 MY EM 3614A HAZARD: INHALATION 1005#

Page 5HAZARD INHALATION 1005#

Page 6HAWKINS INC. US DOT 075303 HAZARD INHALATION 1005#