{"operation":"document","citation":"16-0056","title":"Public Utilities Commission of Ohio — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-03-03","effective_on":null,"summary":"16-0056 response to Public Utilities Commission of Ohio concerning 172.302.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0056.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0056.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0056","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/160056.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMAR 0 3 20l/\nMr. Tom Forbes\nPublic Utilities Commission of Ohio\nTransportation Department\nField Supervisor Enforcement Division\n180 East Broad Street\nSuite 412\nColumbus, OH 43215\nReference No. 16-0056\nDear Mr. Forbes:\nThis letter is in response to your April 8, 2016, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR parts 171-180) applicable to the marking and shipping\npaper requirements for multi-compartment cargo tanks containing petroleum distillate fuels.\nSpecifically, you state that a four-compartment DOT 406 cargo tank motor vehicle (CTMV) is\nused to carry \"NA 1993, Diesel Fuel\" and/or \"UN 1203, Gasoline\" for home delivery service.\nYou further explain that the CTMV has two delivery hose reels, with each having the capacity to\nhold up to 20 gallons of residue product.\nIn your letter, you describe a scenario in which the DOT 406 CTMV transports diesel fuel, or its\nresidue, in all four of the compartments. In addition, one of the reels on the vehicle contains 20\ngallons of diesel fuel, while the other reel contains 20 gallons of gasoline.\nWe have paraphrased and answered your questions as follows:\nQ 1. You ask if the CTMV in the scenario described may display the \"UN 1203\" identification\nnumber since there is gasoline in one reel, or if it must display \"NA 1993\" since there is\ndiesel fuel in the cargo tank compartments.\nA 1. The requirements to display the identification number are based on the contents of the\nauthorized bulk packaging (see § 172.302). Since the cargo tank contains only diesel\nfuel, it must display the \"NA 1993\" identification number.\nQ2. You ask if a shipping paper is required for the gasoline in the reel since the capacity\nexceeds the Materials of Trade (MOTs) exception for Packing Group (PG) II flammables.\nA2. The answer is no. A hose for loading and unloading a DOT specification cargo tank is\nnot designed to contain hazardous material during transportation, but rather to connect\n\n<<<PAGE 2>>>\n\nthe authorized transport packaging to a discharging or receiving container. As it would\nbe impractical to remove all traces of hazardous material residue from these hoses when\nthe vehicles are in transit to deliver product, residue is permitted to remain within them.\nHowever, the residue must be removed to the fullest extent practical.\nFurther, the MOTs exception is n9t applicable in this scenario because the CTMV does\nnot meet one of the three criteria to be considered a MOT (i.e., the principal business is\ntransportation by motor vehicle).\nI hope this information is helpful. Please contact us if we can be of further assistance .\n. 4t~~\n~ZJ\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nGeller, Shelby CTR (PHMSA)\nMonday, April 11, 2016 9:24 AM\nHazmat Interps\nFW: HM Clarification\nDear Shante and Alice,\nForwarded is a request for a formal letter of interpretation. Mr. Forbes mailing address is:\nPublic Utilities Commission -Transportation Department\nAttn: Tom Forbes\n180 E. Broad St, STE 412\nColumbus, OH 43215\nThanks,\nShelby\nFrom: tom. forbes@puc.state.oh.us [mailto:tom.forbes@puc.state.oh. us]\nSent: Friday, April 08, 2016 9:32 AM\nTo: PHMSA HM InfoCenter\nSubject: HM Clarification\nDear Sir or Madame:\nI am requesting a written interpretation/clarification on the transportation requirements under the Hazardous Materials\nRegulations (HMR 49 CFR Parts 171-180). The questions arose after Interpretation 14-0178 was published.\nA carrier is transporting diesel fuel NA 1993 in a 4 compartment home delivery cargo tank today. The home delivery cargo tank\ntransports diesel fuel NA 1993 and/or gasoline UN1203 in different compartments at various times throughout the week. The\ncargo tank has 2 delivery reels attached to the rear. One reel is designated for diesel fuel delivery and the other reel is\ndesignated for gasoline delivery. Depending what they are delivering they use the designated reel. The reel has 100-150 feet of\nhose and can hold up to 20 gallons of product.\nScenario: A 4 compartment DOT 406 cargo tank is transporting 1993 diesel fuel liquid or reside in all 4 compartments. One reel\nhas 20 gallons of diesel fuel in it and the other reel has 20 gallons of gasoline.\nQ-1 Can the cargo tank display 1203 ID numbers since there is gasoline in one reel or must it display 1993 since that is what is\nin the bulk package?\nQ-2 Is a shipping paper required for the gasoline in the reel since the capacity exceeds the material of the trade exception for\nPG II flammables.\nThank you for your assistance on this matter.\nTom Forbes\nPublic Utilities Commission of Ohio\nTransportation Department\nField Supervisor Enforcement Division\nCell (614) 519-2811\n\n<<<PAGE 4>>>\n\nOffice (614) 644-0296\nPUCO.ohio.gov\nl] Q\nThis message and any response to it may constitute a public record and thus may be publicly available to anyone\nwho requests it.\n2","truncated":false,"body_characters":5075}