{"operation":"document","citation":"10-0247","title":"Hazardous Materials Safety Interpretation 10-0247","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-07-26","effective_on":null,"summary":"10-0247 concerning 172.304, 172.406, 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0247.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0247.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0247","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100247.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue SE\nU.S. Department Washington. DC 20590\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJUL 26 2011\nMs. Laura Grove\nTrucking R & L\n600 Gilliam Road\nWilmington, Ohio 45177\nRef. No.: 10-0247\nDear Ms. Grove:\nThis responds to your e-mail regarding the requirements for display ofmarkings, labels, or\nplacards on shipments of hazardous materials (liquids) in accordance with the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). Your company has implemented a\nprogram that uses an insulating blanket to reduce the risk ofhazardous materials freezing.\nSpecifically, you ask if the markings, labels, or placards on the packaging need to be\ntransferred to the outside ofthe blanket.\nThe answer is yes. In accordance with Part 172 ofthe HMR, markings (§172.304), labels\n(§ 172.406) and placards (§ 1712.516) must be unobscured and visible. For a bulk packaging\ncontained in or on a transport vehicle or freight container, ifthe identification number\nmarking on the bulk packaging is not visible, the transport vehicle or freight container must\nbe marked on each side and each end as specified by § 172.332 with the identification\nnumber marking.\nI hope this information is helpful. If we can be of further assistance, please contact us.\nSincerely,\nBen Supko\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carol\nEf1jruYl')\n~nZ. . /DI\nFrom: Lehman, Victoria (PHMSA) ilJllc.t:t.k;II~~\nSent: Monday, November 22, 2010 12:32 PM 1\"1\"0\n0\"\"7\n_\nTo: Drakeford, Carolyn (PHMSA) '\"\n7\nSubject: FW: Hazmat Information Center Feedback: Interpretations (Letters) Issued by PHMSA\nHi Carolyn,\nWe received the following request for a formal letter of interpretation at the Info Center.\nThanks,\nVictoria Lehman\n202-366-1035\n-----Original Message----From:\nPHMSA-Feedback [mailto:PHMSA-Feedback]\nSent: Friday, November 19, 2010 10:09 AM\nTo: PHMSA HM InfoCenter; PHMSA Webmaster\nSubject: Hazmat Information Center Feedback: Interpretations (Letters) Issued by PHMSA\nI wrote this morning to the Information Center and received a call back from Neil who did not\nclearly answer my question and the voicemail stated I could call the S00 number. I then did\nso and spoke with Dirk at 1-S0e-467-4922, who could not provide me with an interpretation.\nMy question is:\nDuring this time of year we implement a program to reduce the risk of freezable liquids of\nhazardous materials/ products during transportation by commercial motor vehicle\n(tractor/trailer).\nOur question is:\nof the blanket?\nDo the markings and labels, placards (bulk shipment), need to be transferred to the outside\nThe blanket is closed on 3 sides and Velcro strapped on one side. If an official requested\nus to remove the blanket so they could visually see that the shipping papers match the\nshipment, in most cases this would be difficult - because our trailers are full from the nose\nto the rear and there is not any room to move freight around to be able to allow a driver to\nclimb into the nose of the trailer and remove the blanket for the official to view the\nfreight.\nIt was my understanding from Dirk that we do not need to transfer the markings and labels as\nlong as the blanket can be easily removed upon an officials request and as long as the\ntrailer was properly placarded and we must have shipping papers to document what is being\ntransported.\nAfter speaking with our operation we would not always be able to comply with the officials\nrequest to remove the blanket. It would depend on the load configuration.\nWe need some clarification on this subject to ensure we are in compliance at all times with\nthe regulations. Please respond in writing to this request.\nName: Laura Grove\nOrganization: Trucking - R + L\n1\n\n<<<PAGE 3>>>\n\nEmail: 19rove@rlcarriers.com\nAddress: 600 Gillam Road\nCity: Wilmington\nZip Code: 45177\nPhone: 800-543-5589~ 1164\nFAX: 937-655-5871\n2","truncated":false,"body_characters":3923}