{"operation":"document","citation":"13-0180","title":"Mr. Tom Alexander — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-11-18","effective_on":null,"summary":"13-0180 concerning 172.336, 173.29.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0180.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0180.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0180","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130180.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D C. 20590\nNOV J 8 20\\3\nMr. Tom Alexander\n5255 Virginia Avenue\nN01ih Charleston, South Carolina 29406-3615\nRef. No.: 13-0180\nDear Mr. Alexander:\nThis responds to your August 27, 2013 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the placarding and\nmarking of cargo tanks containing petroleum distillates. Specifically, your question pertains\nto a cargo tank equipped with two compartments. Compartment #1 contains \"UN 1203,\nGasoline\"; Compartment #2 contains a residue of\"NA 1993, Diesel fuel.\" You ask if the\ncargo tank should display both the \"UN 1203\" and \"NA 1993\" identification numbers when\nin transportation.\nUnder§ 173.29 of the HMR, an empty packaging containing only the residue of a hazardous\nmaterial shall be offered in transportation and transported in the same manner as when it\npreviously contained a greater quantity of hazardous material. In addition, under\n§ 172.3 36( c)( 5), identification numbers are not required for each of the different petroleum\ndistillate fuels transported in a cargo tank if the identification number for the petroleum\ndistillate fuel with the lowest flash point is displayed. Therefore, in your scenario, it would\nbe permitted for the shipper to only display a placard for the petroleum distillate with the\nlowest flash point.\nI trust this satisfies your inquiry. Please contact us ifwe can be offmiher assistance.\nSincerely,\n,·y /1/<'l>~ ~z;&fr=- ----····\n=--=-·--/ f./bU,r,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom: INFOCNTR (PHMSA)\nSent:\nTo:\nSubject: Wednesday, August 28, 2013 4:31 PM\nDrakeford, Carolyn (PHMSA)\nFW: Compartmentalized Trailer Placard interpretation\nHi Carolyn,\nThis caller requested we submit this e-mail as a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Tom Alexander [mailto:tom.alexander@mwv.com]\nSent: Tuesday, August 27, 2013 3:52PM\nTo: INFOCNTR (PHMSA)\nSubject: Compartmentalized Trailer Placard interpretation\nGood afternoon. Am in need of a DOT interpretation.\nWe buy diesel fuel from a local distributor, who uses compartmentalized trailers. They haul gasoline in one of the\ncompartments and diesel in one of the others. We're told they do not carry both compartments loaded at the same\ntime, but after emptying the gasoline one, will go back to their terminal and load the diesel compartment for\ndelivery to us. Thus the issue ....\nI understand that the gasoline compartment must carry the 1203 Flammable placard, as it is residue, but they are\nnot placarding the diesel compartment as a 1993 Combustible. This is causing some concern at our facility on\nmany fronts, as I believe they are misrepresenting the actual Hazard in the package. Also, the 1203 placards\nwould not match the NA 1993, Combustible Liquid NOS paperwork. Emergency response would also be\neffected.\nShould they be carrying 2 different Placards on the Trailer in this case, 1203 and 1993 ?\nHow would we know if they showed up with 1203 only, that they may be introducing gasoline to a our diesel\nstorage tank?\n172.336 outlines a few different scenarios on Identification number requirements but would like to get your input.\nThanks and please let me know if there are any questions or facts that I can further provide\nTom Alexander\n843-740-4427\nThis electronic message contains information from MeadWestvaco Corporation or\nsubsidiary companies, which may be confidential, privileged or otherwise protected\nfrom disclosure. The information is intended to be used solely by the recipient(s)\nnamed. If you are not an intended recipient, be aware that any review, disclosure,\ncopying, distribution or use of this transmission or its contents is prohibited .. If you\nhave received this transmission in error, please notify MeadWestvaco immediately\nat postmaster@mwv.com.\n1","truncated":false,"body_characters":4036}