Crowley Liner Service — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington. DC 1200 New Jersey Avenue SE 20590 Pipeline and Hazardous Administration Materials Safety JUL 0 9 2015 Mr. Michael Lesser Crowley Liner Service 9487 Regency Square Blvd Jacksonville, FL 32225 Reference No. 15-0034 Dear Ms. Lesser: This is response to your February 11, 2015 e-mail and subsequent conversations with members of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. In your letter, you state that your driver receives a loaded intermodal container that is exempt from placarding under § 172.504 but loses the exception by vessel. You ask whether the driver loses the ability to use the exception for placarding by highway if his destination is a port, or may the driver apply the placard (required for vessel transportation) after leaving public roads but prior to entering the port. Shipments of non-bulk combustible materials do not require placards as specified in § 172.504 when shipped under the HMR. However, the HMR does not prevent the use of placards when shipping non-bulk shipments of combustible materials provided the placards appropriately represent the hazard classes being shipped. If placards are required for vessel transportation for a hazardous material that does not require a placard for highway transportation, the placards could be placed on the container at the port prior to transportation by vessel. I hope this satisfies your request. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrews 12.504 Goodall, Shante CTR (PHMSA) lacardin From: Çiccarone, Michael CTR (PHMSA) Sent: 15 - 0084 To: Wednesday, February 11, 2015 3:02 PM Subiect: Hazmat Interps FW: $172.504 Shante/Alice, Please submit this for a formal letter of interpretation. Mr. Lesser spoke with Shelby and Vince Babich. Thanks, Mike From: Lesser, Michael [mailto:Michael.Lesser@crowley.com] To: Ciccarone, Michael CTR (PHMSA) Sent: Wednesday, February 11, 2015 1:43 PM Subject: RE: §172.504 Crowley Liner Service 9487 Regency Square Blvd Jacksonville, Florida 32225 Thank you From: m.ciccarone.ctr@dot.gov [mailto:m.ciccarone.ctr@dot.gov] Sent: Wednesday, February 11, 2015 11:49 AM Subject: RE: §172.504 To: Lesser, Michael Dear Michael, We have received your request for a written letter of interpretation regarding the hazardous materials regulations (49 CFR Parts 171-180). Please include your company's physical address to expedite the submission process. Sincerely, Mike, Hazardous Materials Specialist An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance with 49 CFR 105.20. http://phmsa.dot.gov/hazmat/regs/interps From: Lesser, Michael [mailto: Michael.Lesser@crowley.com] Sent: Tuesday, February 10, 2015 10:01 AM To: PHMSA HM InfoCenter Subject: §172.504 1#

Page 3A driver receives a loaded intermodal container from a shipper with instructions to drive the load to a port. The contents of the container allows the driver to transport over the highway without applying placards under $172.504(1). Does the driver loose this exemption if his destination is a port - or may the driver apply the placards (required for vessel transportation after leaving open access roadways but before entering the port? CMC Michael Lesser PCM MANAGER, HSSE TERMINAL MGMT-JAX (904) 727-2449 Work 904-571-1251 Mobile *******Work: n/a Home Michael.Lesser@crowley.com 2#