FedEx Freight, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration M~R 0 5 2013 Mr. Mike Brust, CDS Manager, Corporate Safety FedEx Freight, Inc. 2200 Forward Drive Harrison, AR 72601 · 1200 New Jersey Avenue, SE Washington, D.C. 20590 Ref. No. 13-0026 Dear Mr. Brust: This responds to your January 25, 2013 request for clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification on the use ofthe DANGEROUS placard in§ 172.504 for two specific shipments. In your letter, you describe a shipment of2,337 pounds of non-bulk cylinders ofUN 1013, compressed gas, Division 2.2, (non-flammable gas) loaded at one facility, and 1,269 pounds of non-bulk pails of UN 1263, Class 3, flammable liquids placed on a trailer. You ask if a NON-FLAMMABLE GAS placard and a DANGEROUS placard on the trailer comply with § 172.504 requirements? The answer to your question is yes. Section 172.504(b) specifies that a transport vehicle containing non-bulk packages with two or more categories of hazardous materials that require different placards specified in table 2 of paragraph (e) of this section may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in table 2 of paragraph (e) of this section. However, when 1,000 kg (2,205 poun.ds} aggregate gross weight or more of one category of material is loaded at one loading facility, the placard specified in table 2 of paragraph (e) of this section for that category must be applied. Based on the scenario you describe, the NON-FLAMMABLE gas placard must be displayed and either the DANGEROUS or FLAMMABLE LIQUID placard may represent the flammable liquid.#

Page 2I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553. Sincerely, Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: To: Subject: Monday, January 28, 2013 1:47PM Drakeford, Carolyn (PHMSA) FW: Request for Interpretation - Placarding Question Hi Carolyn, We received the following request for a formal letter of interpretation. Thanks, Victoria From: Brust, Mike--- Mgr-Corporate Safety--- GO [mailto:mike.brust@FEDEX.COM] Sent: Friday, January 25, 2013 6:41 PM To: Brust, Mike--- Mgr-Corporate Safety--- GO; INFOCNTR (PHMSA) Cc: Richesin, Sandra --- Safety Compliance Specialist --- GO Subject: RE: Request for Interpretation- Placarding Question I corrected my mistake of listing it CFR 49 below to display 49 CFR Thank you Mike Brust, CDS Mgr-Corporate Safety FedEx Freight, Inc. 870-704-5346 From: Brust, Mike--- Mgr-Corporate Safety--- GO Sent: Friday, January 25, 2013 5:14PM To: infocntr@dot.gov Cc: Brust, Mike--- Mgr-Corporate Safety--- GO; Richesin, Sandra--- Safety Compliance Specialist--- GO Subject: Request for Interpretation - Placarding Question January 25, 2013 Pipeline and Hazardous Materials Safety Administration (PHMSA) U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 I would like to have an interpretation concerning the use of the Dangerous placard. We would like to know what the appropriate placards are allowed to be displayed on a trailer containing the following two items: 1#

Page 4The first shipment contained non-bulk cylinders of Non-Flammable Gas class 2.2 that weighed 2,337 lbs loaded at one facility and the second shipment had 1 ,269 lbs of Flammable Liquid class 3 in pails. Can we display a Non-Flammable Gas 2 placard and a Dangerous placard to meet the regulations found in 49 CFR 172.504? Thank you for your time and I will be looking forward to the interpretation to this situation. Mike Brust, CDS Mgr-Corporate Safety FedEx Freight, Inc. 870-704-5346 2#