Department of California Highway Patrol — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S Department Washington, D.C. 20590 400 Seventh Street, S.W. Research Siminsations JUL 1 1998 Mr. R. B. Wood Senior Traffic Officer Ref. No.: 98-0119 Department of California Highway Patrol 32951 Camino Capistrano San Juan Capistrano, CA 92675 Dear Officer Wood: This is in response to your letter requesting clarification of a quantity description on a shipping paper and the shipping description for gasoline. I apologize for the delay in responding. Your questions are paraphrased and answered as follows: Question 1. Would the term 2 steel bins be a proper total quantity description on an shipping paper for a transport vehicle carrying 2 IBC's? The answer is yes. Any container with a maximum capacity greater than 450L (119 gallons) as a receptacle for a liquid, or a maximum net mass greater than 400 kg (882 lbs), and a maximum capacity greater than 450L (119 gallons) as a receptacle for a solid (see § 171.8, bulk packaging) is considered to be a bulk packaging. Section 172.202 (a) (5) states that for bulk packages (e.g., IBCs), some indication of total quantity must be shown; the indication "2 steel bins" is acceptable. Question 2. May a shipper of gasoline insert into the shipping description octane and temperature readings after the packing group and before the total quantity? The answer is yes. Section 172.201 (a) (4) states that the shipping paper may contain additional information about the material provided the information is not inconsistent with the shipping description. The additional information must appear after the basic description required by § 172.202 (a) (1), (2), (3), and (4). I trust this satisfies your inquiry. If this office can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 205/81/1998 09:35 7144874004 CALIF. HWY PATROL PAGE 01/01 • State of Califomia 1714-661-6215 Business, Transportation and Housing Agency 32951 Camino Capistrano Memorandum San Juan capstano, 42675 Date: June 1, 1998 To: Edward Mazzullo US DOT RSPA From: DEPARTMENI OF CALIFORNIA HIGHWAY PATROL CHP Capistrano R.B. Wood 5997 File No.: 690/5997 Subject: INTERPRETATION OF CER 49 172.202A5 Dear Mr. Mazzullo Would the term 2 steel bins be a proper total quantity description on a shipping paper for a transport vehicle carrying 2 IBC's? octane and temperature readings, affer the packing group and before the total quantity? 172.2026 The second question would be, can a shipper for gasoline, insert into the shipping description states that the basic description is in a(1 through 4). Please respond as soon as possible, my Fax is 949 487 4000 Thank you very much for your help. 000l 5997 R. B. Wood Senior Traffic Officer CHP 51WP (Rev, 11-86) OP1076#