Horizon Lines, LLC — 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 SEP 9 2010 Mr. Cliff Bartley Manager Hazardous Materials Horizon Lines, LLC 5800M 1 William Mills Street Jacksonville, FL 32226 Ref. No.: 10-0166 Dear Mr. Bartley: This is in response to your July 22, 2010, letter requesting clarification on marking requirements for bulk packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 180).M Specifically, you ask if the technical name is required as part of the marking on portable tanks in accordance with § 172.326. As provided by § 172.326( a), a portable tank containing a hazardous material must be marked with the proper shipping name for the material as specified in the § 172.101 table on two opposing sides. While marking a technical name in association with the proper shipping name to identify the contents of the material in a portable tank would provide useful information for emergency response purposes, it is not required. I hope this information is helpful. If you have further questions, please contact this office. Sincerely, Ben Supko Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2"'AI HORIZON _________________~ LIN E S 8M Thursday, July 22, 2010 Mr. Ed Mazzullo Director, Office of Hazardous Materials Standards U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor Mail Stop: E21-317 1200 New Jersey Ave., SE Washington, DC 20590 Dear Mr. Mazzullo, We are a domestic ocean carrier providing container containerized cargo to offshore domestic locations. Sometimes, our customers who ship bulk ISO tank cargos have their cargo held up in transportation due to the fact that the "technical name" is not included on two sides of the bulk package. Please provide guidance on whether the technical name is required to be included on the bulk package or ISO cargo tank in conjunction with the Proper Shipping Name. I have reviewed the marking requirements for portable tanks which is listed in 49CFRl72.326(a) pertaining to this issue and states the following: 172.326{a) I/(a) Shipping name. No person may offer for transportation or transport a portable tank containing a hazardous material unless it is legibly marked on two opposing sides with the proper shipping name specified for the material in the § 172.101 table." Since the "proper shipping name" is different from the "technical name", the regulations here seem to indicate that only tne "proper shipping name" IS required fer the marking of the package. Thank you for your time attention to this matter. Sincerely, q£~~-- Horizon Lines, LLC Manager Hazardous Materials Horizon lines. Blount Island. 5800-1 William Mills Street. Jacksonville, FL 32226·904.757.8266· www.horizon·lines.com#