Department of the Army — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration JUL '7 2011 1200 New Jersey Avenue SE Washington. DC 20590 Mr. Joseph Dugan Military Surface Deployment and Distribution Command Department ofthe Army Scott Air Force Base, IL 62225 Ref. No. 11-0053 Dear Mr. Dugan: This'responds to Mr. Maham's March 3, 2011 letter regarding placarding requirements for a freight container system under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and under the International Maritime Dangerous Goods (IMDG) Code. The letter describes a freight container system ("container") consisting of three or four individual units assembled together for ease ofhandling during intermodal transportation commonly referred to as tricons or quadcons, respectively. The assembled containers (Le., the tricon or quadcon) form approved containers in accordance with the International Convention on Safe Containers (CSC) as referenced in the definition of a freight container in the Intern~tional Maritime Dangerous Goods (IMDG) Code and the United States Coast Guard (USCG) regulations (see 49 CFR Part 450). Specifically, the letter includes a request for clarification ofthe placarding requirement for a tricon or quadcon when the individual units contain a mix of hazardous material classes or when the end units contain a mix of hazardous material classes and an interior unit(s) contains no hazardous material. The general placarding requirements under the HMR require the individual units containing hazardous material to display placards on each side and each end (see § 172.504(a)). In lieu of placarding on all four sides, the HMR authorizes freight containers less than 640 fe to display one placard (or label) on the freight container (see § 172.512(b)). As described in Mr. Maham's letter, each individual unit of a tricon or quadcon has a capacity less than 640 fe, thus, under the HMR, each individual unit containing hazardous material must display a placard (or label) representative of the hazardous material it contains. With regard to IMDG placarding requirements, it is our opinion that the CSC-approved containers (Le., the assembled tricon or quadcon) described in your letter are essentially compartmented containers, and thus, may be placarded in the same manner as a multiple-compartment tank containing more than one hazardous material. Such a tank must display placards along each side at the positions of the relevant compartments containing a hazardous material (see 5.3.1.1.4.1.3 of the IMDG Code).#

Page 2Accordingly, a tricon or quadcon displaying placard(s) on each side of an individual unit containing hazardous material satisfies the placarding requirements ofboth the HMR and the IMDG Code. I hope this information is helpfuL If you have further questions, please contact this office. Sincerely, ~S~ Ben Supko Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3ber Klncleren 9 17z. 5Ql/ lQ) DEPARTMENT OF THE ARMY n rei MILITARY SURFACE DEPLOYMENT AND DISTRIBUTION COMMAND 'r'tea t~ 1 SOLDIER WAY I scon AFB, IL 62225·5006 I - 0 0 Directorate of Safety (AMSSD·SA) March 3,2011 U.S. Department of Transportation Pipeline Hazardous Materials Safety Administration Office ofHazardous Materials Safety Office ofHazardous Materials Special Permits and Approvals 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 ATTN: Office ofHazardous Materials Standards (PHH-IO) Dear Sir: In accordance with the provisions of Title 49, Code of Federal Regulations (CFR), Part 105, Section 105.20, the Department of Defense (DOD) hereby requests an Interpretation ofthe Hazardous Materials Regulations as outlined below. DOD petitions for a clarification of 49 CFR 172.504(a), General Placarding Requirements, in particular "Assembled TriconiQuadcon containers shipped as a single unit)". The following file number is assigned: File Number: 25-11 (0303) Re: Request Interpretation of 49 eFR 172.504 (a), General Phlcarding Requirements Proponent: Department ofDefense (DoD) DoD shippers are encountering difficulty in the preparation and transportation ofapproved Internlodal Packagings; the problem is current domestic and international regulatory standards are in conflict regarding the definition ofa container. DoD chooses to use alternate container systems known as a Tricon, which are comprised of three individually constructed units possessing interrnodal fittings that can be assembled into a single 20'container unit; another similar system is in USe known as a Quadcon, which is comprised offour individually constructed units when assembled into a signle 20' container unit fitting the same description as a Tricon. Please see attachments I and 2 respectively for specification descriptions for each. An individual Tricon unit is approx. 96m H x 96"'W x 72S"L with a cubic capacity of356 eu ft. and an area of < 52 sq ft (attachment 3); further an individual Quadcon unit is approx 82" H x 57.375" W x 96"L. with a cubic capacity of258 eu ft, (attac1unent 4). 49 CFR 171,8 defines a Freight Container as a reusable unit of> 64 cu. ft. Domestically, the 49 CFR 171.8 defmition conflicts with the standard proscribed in 49 CFR 450.3 which applies to containers used in international transport. 49 CFR 450.3 defines a container as meeting the requirement for size being at least 75 sq. ft. Internationally the International Maritime Dangerous Goods (IMDG) Code implements the Convention for Safe Containers (esC) describing a container as of a size of at least 75 sq. ft.. Therefore an individual TriconlQuadcon unit may be considered a container if oftered only for domestic transport. Consequently, an individual TriconlQuadcon unit would not be considered a container or CSC approved to be offered for international transport by vessel. 49 CFR 172.504 proscribes each packaging containing any haZlnat must be placarded on each side and each end. IMDG 5.3.1.1.4.1 states a freight container shall clearly display placards on each side and each end. Once DoD assembles a TriconiQuadcon coupling the individual units together to now fonn a single 20' CSC approved freight container, 49 CFR 172.502 (a)(1)(ii) would not apply because the placard on the end Tricon/Quadcon unit accurately represents the hazards within the 20' CSC container. Pflnled an G)Recycled Paper#

Page 4-2When Tricon/Quadcoll unit containers are coupled together to fonn a single esc approved 20' container they must be a placard on each end and each side of the 20' container. Since the act ofcoupling the TriconiQuadcon unit together wiIl obscure at least one side or end, a placard(s) will need to be placed on the opposite end of the Tricol1/Quadcon unit. This will mean that an individual TriconiQuadcon ullit which may not contain any hazmat will have a placard on it. When the TriconlQuadcon assembled unit is decoupled the placard on the non-hazmat Tncon component must be removed immediately; for those remaining component units the appropriate HAZMAT placards must be placed on all four sides of each compent unit. Question: What are the placarding requirements when three/four TriconlQuadcon containrs are assembled into a signJe 20' container unit and loaded on a vehicle or vessel? 1. When all four containers have a mixed Hazard Classification/Division (Hc/D) materials? 2. When the end container units have a mixed HClD and there is 110 HZZMAT in the middJe container of a Tricon or in positions 2 or 3 of a Quadcon? My point of contact for this matter is Mr. Joseph P. Dugan, (618) 220-5040, e-mail sd4c.safb.safety@us .amly.mil or ioseph.dugan@us.army.mil Safety Team, Military Surface Deployment and Distribution Command, ATTN: AMSSD-SA, One Soldier Way, Scott AFB, IL 62225. Daniel A Maham Director ofSafety Encl(s) Attl T ricon description Att2 Quadcon description Att 3 TriCOIl characteristics Att4 Quadcon characteristics#

Page 5TRICON The Tricon modular container is used extensively by the United States Armed forces for its unique and versatile deployability. The Tricon is configured so that when three units are secured together, using the exclusive SeaLock connectors, the resulting package has the same footprint and increased mobility as a standard 20' ISO intermodal container. The Tricon is available I, II, III, IV &Vvariants, providing multiple door locations for increased mission flexibility. Intended for use as atransport/storage unit, the Trieon offers aWide range of options for storage, equipment integrations, specialized security containers, and office modules. The Tricon's all-steel construction and unique versatility make this an ideal new option for military and commercial logistics challenges. Charleston Marine Containers, Inc., a Kratos company, is aleading design, engineering, manufacturer and integrator of modular intermodal, and specialty container systems. CMCI offers high levels of clJstom in-house integration for increased solutions to mission requirements. Strategically located in Charleston SC, CMCI can meet your needs by land, sea or air. Charleston Morine Containers. Inc. AKRitTOS Company#

Page 6qUADCON The Quadcon is aunique and versatile mini-container originally developed for use by the United States Armed Forces. The unit is configured to enable four containers to be secured together using the exclusive Sealock connector. The resulting package has the same footprint as.a standard 20' ISO intermodal container. Alternatively, two Quadcons may be connected together to create a10' ISO container. This four-into-one concept offers the advantages of asegregated loading pattern with the ease of handling of a standard 20' container. Intended for use as a transport/storage unit, the Quadcon's double-door access offers awide range of options for on-site storage sheds, mobile lockers, capital equipment housings, etc. Quadcon's all-steel construction and unique versatility makes It an ideal new option for both commercial and military operations. Charleston Marine Containers, Inc., aKratos company, is aleading design, engineering, manufacturer and integrator of modular intermodal, and specialty container systems. CMCI offers high levels of custom in-house integration for increased solutions to mission requirements. Strategically located in Charleston SC, CMCI can meet your needs Charleston Marine Containers. Inc. ,.._"_,~_.~~tf~~,_~"".""._•...~"~. by land, sea or air. AKRitTOS Company#

Page 7SEABO STANDARD FEATURES: • Corrugated steel sides, roof, & swing doors on one side - Heavy duty steel floor • (4) way fork 11ft pockets • Wall tie down steel lashing rings, 4,000 Ibs. cap, each, (28) total - Front corner post tie downs, (10) total • Door corner post tie downs, (10) total = restraint system, shoring slot will support 2" x 6" lumber • Adjustable shelving brackets: (5) sets =(10) Vertical E-Track sections total - Vents, (2) each OPTIONAL FEATURES: • Manifest Box, (2) each - Connectlng couplers, (3) per Tricon • Connecting coupler storage bracket, (1) each • DeCking and Shoring Beams, (15) each • 383 Green exterior CARC paint (3) Trlcon Containers coupled together to form one 20' ISO module ALL NEW CONTAINERS ARE MANUFACTURED TO THE LATEST ISO STANDARDS Length Height Width Door Opening TRICON Ext. Int. Ext. Int. Ext. Int. Height Width Ft. / In. 6' 51/2" 6' 35116" 8'0' 7' 51/64" 8'0" 7'723132' 7' 1 3/64" 6" 45/64" Metric 1.969 1.913 2.438 2,261 2,438 2.330 2.160 1,872 TRICON Tare Weight Payload Gross Weight Cubic Capacity Lbs. 2.5BO 12,320 14,900 356 Cu. FI. Kg. 1.170 5,590 6,760 10.0 Cu. M. ALL DIMENSIONS AND WEIGHTS ARE NOMINAL AND SUBJECT TO MINOR VARIATIONS THAT MAY OCCUR DURING THE MANUFACTURING PROCESS#