Pioneer Tank Lines, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Pipeline and Hazardous Materials Washington, DC 20590 Safety Administration MAR 1 3 2015 Mr. Larry Nielsen Safety and Compliance Manager Pioneer Tank Lines, Inc. 12501 Hudson Road South Afton, MN 55001 Reference No. 14-0190 Dear Mr. Nielsen: This is in response to your October 6, 2014 email and subsequent telephone conversations with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to segregation requirements for highway transportation. Specifically, you ask if UN 1017 Chlorine must be segregated from other Class 8 (corrosive) liquids for highway transportation. Chlorine is not prohibited from being transported in the same transport vehicle as Class 8 materials provided the separation requirements in § 177.848(e)(3) are complied with. These materials may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that, in the event of leakage from packages under conditions normally incident to transportation, commingling of hazardous materials would not occur. In your incoming request you note that the second half of § 177.848(e)(3) states "Notwithstanding the methods of separation employed, Class 8 (corrosive) liquids may not be loaded above or adjacent to Class 4 (flammable) or Class 5 (oxidizing) materials; except that shippers may load truckload shipments of such materials together when it is known that the mixture of contents would not cause a fire or a dangerous evolution of heat or gas." You ask if this exception would apply to a load containing UN 1017 Chlorine and a Class 8 liquid apply. material. As UN 1017 Chlorine is a Division 2.3 (Zone B) material, this exception does not I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Plane A. Poin International Standards Coordinator Standards and Rulemaking Division#

Page 2weso $177,848 segregation Dodd, Alice (PHMSA) 4-0190 From: Sent: Ciccarone, Michael CTR (PHMSA) To: Tuesday, October 07, 2014 2:47 PM Subject: Hazmat Interps FW: Clarification of Interpretation 08-0143 Shante and Alice, Please submit this for a formal letter of interpretation. Mr. Nielsen spoke to Adam Lucas and Shelby Geller in the HMIC. His company address is: 12501 Hudson Road South Afton, MN 55001-9751 Thanks, Mike From: larry [mailto:larryn@pioneertanklines.com] Sent: Monday, October 06, 2014 4:43 PM To: INFOCNTR (PHMSA) Subject: Clarification of Interpretation 08-0143 I am requesting further clarification of the referenced interpretation, specifically if Chlorine, UN 1017, Class 2.3, 8, 5.1 (POISON INHALATION HAZARD) must be segregated from Class 8 liquids. The letter from the requestor states in part "3. In addition, we are under the impression that if the products do NOT create a hazardous condition when comingled, then the materials may be adjacent to each other, if the mixture would not cause a fire or a dangerous evolution of heat or gas, based upon 177.848.(e)(3) and Interpretation 03-0146." 177.848(e)(3) reads in part "Notwithstanding the methods of separation employed, Class 8 (corrosive) liquids may not be loaded above or adjacent to Class 4 (flammable) or Class 5 (oxidizing) material; except that shippers may load truckload shipments of such materials together when it is known that the mixture of contents would not cause a fire or a dangerous evolution of heat or gas". It is my interpretation that this portion of 177.848(e)(3) applies ONLY to the segregation of Classes 4, 8, and 5 and would not apply to the separation or segregation of Class 2.3 from Class 8 or Class 5.1. Please issue your clarification at your earliest convenience. Thank you. Larry Nielsen Safety and Compliance Manager Pioneer Tank Lines, Inc. Phone 651-436-8296 Fax 651-436-8929 larryn@pioneertanklines.com www.pioneertanklines.com 1#