GP Trucking — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration SEP 0 9 2014 Mr. John Billingsley GP Trucking 125 Access Road Gaston, SC 29053 Ref. No. 14-0130 Dear Mr. Billingsley: This is a response to your June 30, 2014 email requesting clarification of general requirements for loading and unloading under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on whether failure to secure the non-hazardous cargo in a mixed hazardous and non-hazardous shipment would be a violation of § 177.834. The answer is no. The requirements found in § 177.834 are applicable to the carriage of packages containing hazardous materials by highway. However, in accordance with § 177.804(a), compliance with applicable Federal Motor Carrier Safety Regulations (FMCSR) is required. Regulations covering protection against shifting and falling cargo can be found in 49 CFR Part 393, Subpart I. I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Acting Chief, Standards Development Standards and Rulemaking Division#

Page 2Suchat 177.834 Dodd, Alice (PHMSA) General Requirements 14-0130 From: INFOCNTR (PHMSA) Sent: To: Monday, June 30, 2014 3:47 PM Subject: Hazmat Interps FW: Hazmat Information Center Feedback: Specifications for Packagings (Sections 178.1 – 178.819) This caller requested we submit this e-mail as a formal letter of interpretation for a written response. Thanks, Victoria --Original Message-- From: PHMSA Webmaster Sent: Monday, June 30, 2014 12:22 PM Tọ: PHMSA HM InfoCenter; PHMSA Webmaster Subject: Hazmat Information Center Feedback: Specifications for Packagings (Sections 178.1 – 178.819) When carrying Hazardous and non-hazardous materials in a towed unit, would failing to secure the non-hazardous portion of the load be considered a violation of 177.834? Name: John Billingsley Email: bilj@gptruck.com Organization: Phone: 803.936.8585 FAX: 1#

Page 3Suchak, Neal (PHMSA) From: Bomgardner, Paul (FMCSA) Sent: Thursday, August 28, 2014 9:21 AM To: Suchak, Neal (PHMSA); Hardridge, John (FMCSA) Cc: Rach, Suzanne (FMCSA) Subject: RE: Interp for review Neal: Pretty much sums it up. I concur. Thanks, Paul From: Suchak, Neal (PHMSA) Sent: Thursday, August 28, 2014 9:01 AM To: Hardridge, John (FMCSA) Cc: Bomgardner, Paul (FMCSA); Rach, Suzanne (FMCSA) Subject: Interp for review Good morning, Would you all mind reviewing the attached interp and providing comment/FMCSA concurrence? It's fairly simple this time (no cargo tanks!). As always, I appreciate your time and input! Thanks. Respectfully, Neal Suchak 1#