Wisconsin State Patrol — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, DC 20590 1200 New Jersey Avenue, SE Pipeline and Hazardous Materials Safety Administration APR 0 2 2018 Mr. Karl Kronau Wisconsin State Patrol 911 W. North Street Deforest, WI 53532 Reference No. 16-0191 Dear Mr. Kronau: This letter is in response to your November 17, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to required marking(s) of the inlet/outlets) on MC331 cargo tank motor vehicles as it relates to a previously-issued letter of interpretation. You also provided photographs for reférence. We have paraphrased and answered your questions as follows: Q1. You ask whether the marking requirement in § 178.337-9(c), which requires each cargo tank inlet and outlet to be marked "liquid" or "vapor" to designate whether it communicates with liquid or vapor when the cargo tank is filled to the maximum permitted filling density, may be satisfied if the markings are placed on the accident damage protection frame. A1. The answer is yes. Provided the marking is readily visible, legible, durable to withstand transport conditions, and clearly associated with the corresponding inlet or outlet, the marking would satisfy the requirements of the HMR. Q2. You ask whether communicating "liquid" or "vapor" markings using durable tags attached by a wire that hangs loosely but is secured to the piping, outlet, or valve is an acceptable method of marking the cargo tank inlet and outlet in accordance with § 178.337-9(c). A2. See Al. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Heal Shane Kelley Director Standards and Rulemaking Division#

Page 2asey 178.337-910 Dodd, Alice (PHMSA) Packaging specs From: INFOCNTR (PHMSA) 76-0197 Sent: Friday, November 18, 2016 2:03 PM To: Hazmat Interps Subject: FW: Formal letter of Interpretation request Follow Up Flag: Follow up Flag Status: Flagged Hi Shante/Alice, Please submit this as a letter of interpretation. Mr. Kronau spoke with Jodi. Please note this clarification is in relation to Ref. No. 16-0001. Please let me know if you have any questions. Thanks, Jordan From: Kronau, Karl - DOT [mailto:Karl.Kronau@dot.wi.gov] To: INFOCNTR (PHMSA) Sent: Thursday, November 17, 2016 4:28 PM Subject: Formal letter of Interpretation request Cc: Maxson, Anne - DOT; Johnson, Jeremiah - DOT I am requesting a formal letter of interpretation or a letter of clarification of your recent Interpretation (16-0001) regarding 49CFR178.337-9(c) as it relates to the requirement of an MC331 cargo tank inlet and outlet to be marked "liquid" or "vapor". In your interpretation you state that compliance would be achieved when, "The required markings must be on the inlet and outlet equipment itself and in close proximity to its respective make/break connection point, rather than on the cargo tank wall." Question1: Is the "equipment" inclusive of the accident protection required under 178.337-10? Would a cargo tank with the "Vapor", "Liquid" markings placed on the accident protection frame (see photos below), and in close proximity of the inlets/outlet make break connection be in compliance of 178.337-9(c)? 1#

Page 3MISSISSIT1 ANI COMPANY#

Page 4Question 2: Would the "Liquid", "Vapor" markings on a durable tag that is wired tied (hanging loose, but secure) to the piping, outlet, or valve handle close to the make break connection be in compliance? Or do they need to be rigidly attached? Sincerely Wisconsin State Patrol Southwest Region 911 W. north St. Deforest, WI 53532 HQ(608) 846-8500 karl.kronau@dot.wi.gov 3#