Commerical Motor Vehicle Roadside Inspection — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 JUN 0 5 2014 Mr. William Scott Burson Crash Investigator Commercial Motor Vehicle Roadside Inspection Denton Police Department 601 E Hickory St., Suite E Denton, TX 76205 Reference No. 13-0206 Dear Mr. Burson: This is in response to your October 31, 2013 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to identification numbers on Intermediate Bulk Containers (IBCs). In your scenario, a 500 gallon IBC containing a Class 8 corrosive liquid is transported on an open-sided flatbed truck. The IBC has the correct United Nations (UN) identification number on orange panels on two opposing sides in accordance with§ 172.302(a)(2). These identification numbers are viewable from either side of the flatbed. You ask if the flatbed is also required to display the UN identification numbers on the front and rear of the vehicle. The answer is no. As prescribed in § 172.302(a), bulk packages with a capacity of less than 1,000 gallons capacity are required to display identification numbers only on two opposing sides. For bulk packages of 1,000 gallons capacity or more, identification numbers must be displayed on all four sides. I hope this satisfies your request. Sincerely, J/ ~---L_ ,---'/f;/'I,:Ci,?t/Jt...-~C:;M"~ ----- ...... T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Thursday, October 31, 2013 4:48 PM Drakeford, Carolyn (PHMSA) FW: Interpretation request: 172.331 (c) 13-0200 Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria -----Original Message----- From: Burson, WilliamS [mailto:] Sent: Wednesday, October 30, 2013 5:10 PM To: PHMSA HM InfoCenter Subject: Interpretation request: 172.331(c) PHMSA, I'm requesting an interpretation (or written guidance) concerning required vehicle markings when transporting a bulk package per 172.331(c). The scenario is thus: A single 500-gallon IBC of corrosive liquid is transported on an open-sided flatbed. The IBC has the correct UN identification number on orange panels on two opposing sides per 172.302(a)(2). The UN identification number on the IBC is visible to an observer standing to either side of the flatbed. Is the flatbed carrying the IBC also required to display the UN identification number on the front and rear of the vehicle? Again, [worded slightly differently] when considering a open-sided flatbed carrying a properly marked 500-gallon IBC, and the UN identification numbers on the IBC are visible to an observer on either side of the flatbed, does the flatbed also require UN identification numbers on the front and rear of the vehicle? Thank you. Wm Scott Burson Crash Investigator/Commercial Motor Vehicle Roadside Inspector Denton Police Department 601 E Hickory St, Ste E Denton, Texas 76205 Main: 940/349-8181 Office: 940/349-7851 CONFIDENTIALITY NOTICE: This e-mail and any files accompanying its transmission are intended only for the recipient to whom they are addressed. This transmission may be strictly confidential. If you are not the intended recipient of this message, you may not disclose, print, copy, or disseminate this information. If you have received this in error, please notify the sender (only) and delete the message. Unauthorized interception, disclosure, copying, forwarding, or other distribution of this e-mail, including its attachments, is a violation of federal criminal law. This communication does not reflect an intention by the sender or the sender's client or principal to conduct a transaction or make any agreement by electronic means. Nothing contained in this message or in any attachment shall satisfy the requirements for a writing, and nothing contained herein shall constitute a contract or electronic signature under the 1#

Page 3Electronic Signatures in Global and National Commerce Act, any version of the Uniform Electronic Transactions Act or any other statute governing electronic transactions. Thank you for your cooperation. 2#