Hazardous Materials Safety Interpretation 10-0247

Page 11200 New Jersey Avenue SE U.S. Department Washington. DC 20590 of Transportation Pipeline and Hazardous Materials Safety Administration JUL 26 2011 Ms. Laura Grove Trucking R & L 600 Gilliam Road Wilmington, Ohio 45177 Ref. No.: 10-0247 Dear Ms. Grove: This responds to your e-mail regarding the requirements for display ofmarkings, labels, or placards on shipments of hazardous materials (liquids) in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company has implemented a program that uses an insulating blanket to reduce the risk ofhazardous materials freezing. Specifically, you ask if the markings, labels, or placards on the packaging need to be transferred to the outside ofthe blanket. The answer is yes. In accordance with Part 172 ofthe HMR, markings (§172.304), labels (§ 172.406) and placards (§ 1712.516) must be unobscured and visible. For a bulk packaging contained in or on a transport vehicle or freight container, ifthe identification number marking on the bulk packaging is not visible, the transport vehicle or freight container must be marked on each side and each end as specified by § 172.332 with the identification number marking. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Ben Supko Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Drakeford, Carol Ef1jruYl') ~nZ. . /DI From: Lehman, Victoria (PHMSA) ilJllc.t:t.k;II~~ Sent: Monday, November 22, 2010 12:32 PM 1"1"0 0""7 _ To: Drakeford, Carolyn (PHMSA) '" 7 Subject: FW: Hazmat Information Center Feedback: Interpretations (Letters) Issued by PHMSA Hi Carolyn, We received the following request for a formal letter of interpretation at the Info Center. Thanks, Victoria Lehman 202-366-1035 -----Original Message----From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: Friday, November 19, 2010 10:09 AM To: PHMSA HM InfoCenter; PHMSA Webmaster Subject: Hazmat Information Center Feedback: Interpretations (Letters) Issued by PHMSA I wrote this morning to the Information Center and received a call back from Neil who did not clearly answer my question and the voicemail stated I could call the S00 number. I then did so and spoke with Dirk at 1-S0e-467-4922, who could not provide me with an interpretation. My question is: During this time of year we implement a program to reduce the risk of freezable liquids of hazardous materials/ products during transportation by commercial motor vehicle (tractor/trailer). Our question is: of the blanket? Do the markings and labels, placards (bulk shipment), need to be transferred to the outside The blanket is closed on 3 sides and Velcro strapped on one side. If an official requested us to remove the blanket so they could visually see that the shipping papers match the shipment, in most cases this would be difficult - because our trailers are full from the nose to the rear and there is not any room to move freight around to be able to allow a driver to climb into the nose of the trailer and remove the blanket for the official to view the freight. It was my understanding from Dirk that we do not need to transfer the markings and labels as long as the blanket can be easily removed upon an officials request and as long as the trailer was properly placarded and we must have shipping papers to document what is being transported. After speaking with our operation we would not always be able to comply with the officials request to remove the blanket. It would depend on the load configuration. We need some clarification on this subject to ensure we are in compliance at all times with the regulations. Please respond in writing to this request. Name: Laura Grove Organization: Trucking - R + L 1#

Page 3Email: 19rove@rlcarriers.com Address: 600 Gillam Road City: Wilmington Zip Code: 45177 Phone: 800-543-5589~ 1164 FAX: 937-655-5871 2#