# Shore Side Safety and Hazardous Material Reviews — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 13-0025
- **title:** Shore Side Safety and Hazardous Material Reviews — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2013-04-17
- **effective on:** Not available
- **summary:** 13-0025 response to Shore Side Safety and Hazardous Material Reviews concerning 172.504.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0025.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0025.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0025
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130025.pdf
**body:**

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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
1200 New Jersey Ave, S.E.
Washington, D.C. 20590
Michael Lesser
Shore Side Safety
and Hazardous Material Reviews
9487 Regency Square Blvd
Jacksonville, Florida 32225
APR 1 7 2013
Ref. No. 13-0025
Dear Mr. Lesser:
This responds to your January 23, 2013 e-mail requesting clarification of the Hazardous Materials
Regulations (HMR; 49CFR Parts 171-180) applicable to use ofthe DANGEROUS placard. Your
questions are paraphrased and answered as follows:
Ql. Recently, there have been a number ofrulemaking actions resulting in further alignment
(harmonization) of the HMR with the various international standards. Does the Pipeline and
Hazardous Materials Safety Administration (PHMSA) intend to phase-out the DANGEROUS
placard as a result of it not being recognized in international transportation?
AI. The answer is no.
Q2. If vessel transportation of a cargo transport unit (CTU) containing hazardous materials is
routed through a foreign port but originates and terminates within the United States, is the
DANGEROUS placard authorized display in accordance with the HMR?
A2. The answer is no. The DANGEROUS placard is not recognized by the International
Dangerous Goods Code (IMDG Code). However, the display of both the DANGEROUS
placard and placard(s) corresponding to the actual hazardous material contained in the CTU is
authorized.
Q3. Is display of the DANGEROUS placard authorized in domestic transportation by vessel?
A3. The answer is yes.
I hope this information is helpful. Please contact this office should you have additional questions.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

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- Drakeford, Carolyn (PHMSA)
From: INFOCNTR (PHMSA)
Sent:
To:
Wednesday, January 23, 2013 2:20PM
Drakeford, Carolyn (PHMSA)
Subject: FW: PHMSA Interpretations
Hi Carolyn,
We received the following request for a formal letter of interpretation.
Thanks,
Victoria
From: Lesser, Michael [mailto:Michaei.Lesser@crowley.com]
Sent: Tuesday, January 22, 2013 2:48 PM
To: INFOCNTR (PHMSA)
Subject: PHMSA Interpretations
Please advise answers to the following questions. These points were raised in a USCG inspection
a. b. c. Is there a date after which he "Dangerous" placard may not be used? Is it being phased out during the harmonization
process?
If a shipment is labeled "Dangerous" and leaves a domestic port- but the vessel calls on an international port before the
container is discharged at the next domestic port- is the container marked properly? Or does IMDG regulations prevail since
they do not recognize the "Dangerous" marking?
Is the "Dangerous" marking permissible on vessels serving domestic ports?
Michael Lesser
Shore Side Safety and Hazardous Material Reviews
904-727-2449 fax 904-727-2185
Michael. Lesser@Crowley.com
"If you really want to do something, you will find a way; if you don't, you will find an excuse."
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