Universal Well Services, Inc. — 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 JAN 2 7 2014 Mr. Tom Cloud Universal Well Services, Inc. 18360 Technology Drive Box4 Meadville, PA 16335 Ref. No. 13-0230 Dear Mr. Cloud: This responds to your November 19, 2013, request for clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if placing a sign to designate a non-hazardous material being transported in a placard holder is authorized under the HMR. In your incoming letter, you state that you intend to use a placard holder to indicate a non- hazardous material, a type of sand, being transported on sand haulers. The placard holder will be positioned in a square rather than a square-on-point orientation. You will insert clear plexiglass with the grade of sand printed on the plaxiglass into the placard holder (See enclosed photographs). The purpose of the sign is, during the unloading process, to alert the driver of a vehicle behind the sand hauler of the specific type sand to be unloaded. You ask if this is authorized under the HMR. Section 172.502(a)(2) provides that: [N]o person may affix or display on a packaging, freight container, unit load device, motor vehicle or rail car. .. any sign, advertisement, slogan (such as "Drive Safely"), or device that, by its color, design, shape, or content, could be confused with any placard prescribed in this subpart. This prohibition is intended to limit the potential dilution of hazard communication provided by the appropriate hazardous materials placards. The display described in your letter and shown in the enclosed photographs is not similar to hazardous materials placards, and would not be confused with prescribed placards in the HMR. Therefore, the display described in your letter and shown in the enclosed photographs would not be prohibited under § 172.502( a)(2). I hope this answers your inquiry. If you need additional assistance, please contact this office at (209)366-8553. Sincerely, 7~23~ Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2'Eco-1-he BllZ-· 51~, 171 a Ctlrd' ~C1 () REQUEST FOR INTERPRETATION FROM PHMSA - PLACARD HOLDER FOR SAND SIGN I . 3-l)~3 Universal Well Services, Inc. is a pressure pumping company in the oil and gas field industry. We transport hazardous materials. We have a regulation placard holder that we want to use as a holder for our sand haulers. The sign within the holder will designate the type of sand being hauled. We transport three different grades of sand. The sign within the holder will be placed on the lower rear of the sand hauler (see enclosed photo). It will be placed on the vehicle not in square on point (as a hazmat placard would), so as not to be confused with a hazmat placard. The purpose of the sign is to alert the driver of the pumper vehicle behind it that the sand it will be receiving from the hauler is the correct type for the job stage coming up. The insert into the placard holder is a clear plexiglass. The grade of sand is printed on the plexiglass. A photo is attached as an illustration. IS USING THE PLACARD HOLDER IN THIS MANNER IN CONFLICT WITH THE HAZMAT REGULATIONS OR DO WE HAVE TO COME UP WITH A DIFFERENT TYPE OF HOLDER SO AS TO AVOID ANY CONFUSION? . I l!v.L..,.. t/i:f;.( 5'1/ L t,j ElL 5 6f tlzz.;JE ~ ~ v' C, I ~3 &D 1 Ecf/t/tiLtJb-y JJ/?. 1 Box')/ !JJE/)DJCtlE ~4 lb33C;- / ---- ------------------ ----------#

Page 3BAND SAMO#

Page 4Tom Cloud From: Sent: To: Subject: Chuck Curry Monday, November 04, 2013 11 :53 AM Tom Cloud Pies Sent from the Samsung Galaxy Rugby Pro, an AT&T LTE smartphone .j .I l - .f--- - 1#