{"operation":"document","citation":"18-0023","title":"GATE Petroleum Comapany — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-02-07","effective_on":null,"summary":"18-0023 response to GATE Petroleum Comapany concerning 172.336.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0023.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0023.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0023","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/70566/180023.pdf","body":"<<<PAGE 1>>>\n\n0\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nFEB O 7 2019\nPatricia Carson\nGA TE Petroleum Company\n9540 San Jose Boulevard\nP.O. Box 23627\nJacksonville, FL 32241-3627\nReference No. 18-0023\nDear Ms. Carson:\nThis letter is in response to your February 21, 2018, email and subsequent phone conversations\nrequesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)\napplicable to marking and placarding of cargo tanks. You state that you typically transport\n\"UN1203, Gasoline\" and \"UN1202, Fuel oil\" to customers in multi-compartmented cargo tanks,\nbut you have recently begun transporting \"UN3475, Ethanol and gasoline mixture\" in full loads,\nchanging out the identification markings to UN34 7 5. You now want to transport both UN 1203\nand UN3475-sometimes with or without diesel-in different compartments in the same load.\nYour questions are summarized and answered as follows:\nQ 1. You ask if the UNI 203 identification marking supersedes all other markings for the\n. petroleum products because it has the lowest flash point or if you must display both\nUN1203 and UN3475 identification markings.\nAl. In accordance with§ l 72.336(c), identification numbers are not required for each of the\n. different petroleum distillate fuels in a compartmented cargo tank if the identification\nnumber for the petroleum distillate fuel with the lowest flash point is displayed.\nHowever, § l 72.336(c) states that if the cargo tank also contains gasoline and alcohol fuel\nblends consisting of more than 10% ethanol, \"UN3475\" or \"UN1987\" must also be\ndisplayed, as appropriate.\n· Q2. If \"UN3475, Ethanol and gasoline mixture\" and \"UN1203, Gasoline\" are alternated\nbetween compartments in the compartmented cargo tank, you ask if each compartment\nmust be marked and placarded.\nA2. The answer is no. While§ l 72.336(c) does require that the compartmented cargo tank\nvehicle display the identification numbers for both UN3475 and UN1203, there is no\nrequirement for the markings or placards to appear on each compartment.\n\n<<<PAGE 2>>>\n\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\n-A V'C(~l/\\JS '\nl>\\a.carolcnq\ncg- 0023\nJanuary, lkeya CTR (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nINFOCNTR (PHMSA)\nWednesday, February 21, 2018 4:51 PM\nHazmat Interps\nFW: Interpretation Letter Request\nHello all,\nPlease see the below interp request. I spoke to the caller and provided her three LOl's: 06-0203, 16-0020, & 14-0178,\nbut she is looking for an interp that fits her situation exactly. Also, she has another question:\nIf the if the compartmentalized cargo motor vehicle has only two products~34; and ~, but they are\nalternated, does each section have to be marked/placarded, or would the two placards/marks suffice?\nv -\n.\nRegards,\n-Breanna\nFrom: Patricia Carson [mailto:pcarson@gatepetro.com]\nSent: Wednesday, February 21, 2018 12:52 PM\nTo: PHMSA HM lnfoCenter <PHMSAHMlnfoCenter@dot.gov>\nSubject: Interpretation Letter Request\nU. S. DOT\nAttn : PHH-10\nEast Building\n1200 New Jersey Ave, SE.\nWashington, DC 20590\nTo Whom It may Concern:\nI work for a Hazmat fuel carrier and we are expanding the various product to which we haul. Normally we carry Gasoline\n(with <10% ethyl alcohol) (UN1203) and/or Fuel Oil (NA1993 or UN1202) to our customers in a multi compartmented\ntrailer (DOT 407). We have started to carry Gasoline \"E85\" (with >10% ethyl alcohol) (UN3475) in full loads so we change\nout our placards to Flammable-UN3475.\nDispatch now wants to haul both types of Gasoline, sometimes with or without diesel, in the different compartments\nper load. Does the 1203 supersede all other placards because of the flashpoint or do we have to display both 1203 &\n3475 placards on the sides of the trailer with the generic flammable placard on the front and back? Being that it is all\nClass 3, flammable liquids, I was unsure of the placard markings. Is there anything else that we need to do differently\nwhen hauling these 2 types of gasoline together on one unit?\nThank you for the opportunity to ask this question.\nPat Carson\nSafety Coordinator\nP.904.448.7037\n1\n\n<<<PAGE 4>>>\n\nF.904.448. 7055\nPCarson@gatepetro.com\nCONFIDENTIALITY NOTICE: The information and all attachments contained in this electronic communication are\nconfidential, proprietary and may constitute trade secrets under applicable law. They are intended solely for use by the\nindividual or entity to which they are correctly addressed and were intended to be sent. Any review, use, dissemination,\ndistribution or copying of this communication by anyone other than its intended recipient is strictly prohibited and may\nviolate applicable law. If you received this message in error, please notify us immediately by return e-mail to the address\nbelow and permanently remove any copies of this message from your system and do not retain any copies, whether in\nelectronic or physical form or otherwise. GATE Petroleum Company accepts no liability for the content of this email, or\nfor the consequences of any actions taken on the basis of the information provided herein. GATE Petroleum Company,\n9540 San Jose Blvd., Jacksonville, Florida 32257, GATE-inquiry@GATEpetro.com\n2","truncated":false,"body_characters":5395}