JEVIC Transportation Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Research and Washington, D.C. 20590 Administration Special Programs SEP 30 1998 Mr. Samuel V. Yardumian JEVIC Transportation Inc. Ref. No. 98-0263 P.O. Box 5157 Delanco, NJ 08075 Dear Mi, Yardumian; • This is in response to your letter dated September 1, 1998, regarding clarification of the requirements in 49 CFR 172.301(a)(3) for identification number markings on transport vehicles containing large quantities of hazardous materials in non-bulk packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided the following scenarios and questions: Q1. Vehicle contains 2,500 kg of "Paint, 3, UN 1263, PG II" in non-bulk containers loaded at one location. A FLAMMABLE placard is applied to the vehicle. At the next stop, loaded 2,500 kg of "Paint, 3 UN 1263, PG II" on the same vehicle. Is it necessary to mark the vehicle with the "1263" identification number? A1: No. Display of the identification number markings on each transport vehicle or freight container is only required when: 1) each non-bulk package is marked with the same proper shipping name and identification number; 2) the aggregate gross weight of the hazardous material is 4,000 kg (8,820 1bs.) or more; 3) all of the hazardous material is loaded at one loading facility; and 4) the transport vehicle or freight container contains no other material, hazardous or non- hazardous [Docket HM-206; Final rule; 62 FR1217; 01/08/97; corrections and editorial changes; 62 FR 39398; 07/22/97; and 62 FR 16070; 04/ 01/98]. Q2. Vehicle contains 2,500 kg of "Printing ink, 3, UN 1210, PG II" in non-bulk containers. At another location, 5,000 kg of "Paint, 3, UN 1263, PG II" in non-bulk containers is loaded on the same vehicle. Is only the FLAMMABLE placard required, or is the "1263" identification number marking also required to be displayed? A2. Only the FLAMMABLE placard is required. Q3. Vehicle contains some non-hazardous freight. At another location, the vehicle is loaded with 5,000 kg of "Paint, 3, UN 1263, PG II" in non-bulk containers. In addition to the FLAMMABLE placard, is it necessary to mark the vehicle with the "1263" identification number?#

Page 2A3. No. See "Answer 1" above. Q4. Vehicle contains 5,000 kg of "Paint, 3, UN 1263, PG I" in non-bulk containers loaded at one location. The FLAMMABLE placard, marked with the identification number, is applied to the vehicle. At the next stop, 5000 kg of "Printing ink 3, UN 1210, PG II" is loaded on the same vehicle. May an unmarked FLAMMABLE placard be used for the entire load? A4. Yes. I hope this satisfies your inquiry. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3-(609)-461-7111 FAX (609) 764-6761 JEVIC (800) 257-0427 TRANSPORTATION INC. 98-0263 600 Creek Road, PO Box 5157 Delanco, NJ 08075 Engrum § 172.301 Mr. Delmer Billings, Chief, Standards Development Office of Hazardous Materials Standards U.S. Department of Transportation Room 8102 Washington DC 20590 400 Seventh St., SW September 1, 1998 - Dear Mr. Billings: Jevic Transportation, Inc. is in the process of reviewing new Hazardous Materials training materials it has developed for its drivers and support personnel. In order to ensure clarity of the training, examples of placarding under the current regulations are scenarios are causing some question of accuracy among ourselves. For that reason, given using hypothetical but not atypical scenarios. Unfortunately, a few of the we desire to submit several of them to you for your consideration and opinion. Scenario 1 non-bulk containers loaded at one location. The FLAMMABLE placard, Begin with a vehicle containing 2,500 kg. of "Paint, 3, UN 1263, PG I" in is applied to the vehicle. At the next stop an additional 2,500 kg, of "Paint, 3, UN 1263, the vehicle with the "1263" marking? PG I'" in non-bulk containers is loaded into the same vehicle. Is it now necessary mark No Begin with a vehicle containing 2,500 kg. of "Printing ink, 3, UN 1210, sure, is me 265 haking now requed Wil the FLAMMABLE placar ine pe mater PG If" in non-bulk containers. At another location 5,000 kg. of "Paint; 3, suffice, or is the "1263" marking-now required? Scenario 3 Beginning with a vehicle containing some non-hazardous freight, a stop is made at which 5,000 kg. of "Paint, 3, UN 1263, PG I!" in non-bulk the vehicle with the "1263" marking? containers is loaded. In addition to the FLAMMABLE placard, is it now necessary mark NO. Scenario 4 non-bulk containers loaded at one location. The FLAMMABLE placard, Begin with a vehicle containing 5,000 kg. of "Paint, 3, UN 1263, PG II" in marked with the I.D. number 1263 is applied to the vehicle. At the next stop, 5,000 kg. of "Printing ink, 3, UN 1210, PG II," also non-bulk, is added to the load. May an placards/markings would be required? What, if any, alternatives might be permissible?#

Page 4clarification or comment you may offer on them. We thank you in advance for your consideration of these questions and appreciate any Sincerely, Samuel V. Yardumian J Hazardous Materials Specialist (800) 257-0427 (609) 461-7111 Ext. 6230 •- ---#

Page 5..... • My interpretation of this rule is that option "2" would apply, since there is more than a single lazardous product on board. Furthermore, my understanding of the 4000 kg(8820 Ibs) ruling pplies only when that is the only product on the truck and total weight, in non-bulk packages exceeds 4000 kg. Xour clarification would be greatly appreciated. Sincerely, Kevin Walker Plant Manager -#