Mr. Patrick G. Kruger — Hazardous Materials Safety Interpretation

Page 1• U.S.Department of Transportation 400 Seventh Street, S.W Research and Washington, D.C. 20590 Special Programs Administration MAR - 4 ISSS : Mr. Patrick G. Kruger 298 Mendham Road. Morristown, New Jersey 07960-4805 Dear Mr. Kruger: This is in response to your letter regarding clarification of the requirements for the display of old and new placards for explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). I apologize for the delay in responding and hope it has not caused any inconvenience. As provided by § 171.14(b), until October 1, 2001, placards which conform to specifications for placards in effect on September 30, 1991, or placards specified in the December 21 1990 final rule may be used, for highway transportation only, in place of the placards specified in Ducted with the "Placard Substitution Table." Therefore, the old or new placards may currently be used for explosives under the described conditions. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2SENT BYiXerox Telecopier 7021 : 6-28-97 ; 8:20 ¡SPECIAL SERVICES DIV→ 202 366 7342:# 2 Englum - 1172500,173,51 Fili: SC: 270,136,140 • US. DEPT. OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS OFFICE OF HAZARDOUS MATERIALS ADMINISTRATION INITIATIVES AND TRAINING (DHM-50) WASHINGTON, DC 20590 - 0001 26 JUNE 1997 Sirs; the other day. One oi the questions about class 1 exprosiver I just taken a NJ Dept of Motox Vehicle Hazmat retest was, in essence, A vehicle with 1,1 explosives and 1.! axplosives should be placarded;. The correat answer according to NJ was explosive A. years and currently I have been in the the NJ National Guară for over 22 (artillery). At various ammunition storage areas they all working in the ammunition section Placarás were superceded aná no longer legal for use on stated that as of september of 1995 the "A,B, C" EXPLOSIVE public roads. I might ad that these AsA's are run by the us Army not the This has set up much confusion to me as to what is the state of Nu. proper placard and it the old signs are still ok to use. I have coplas of CFR 49 100 -177 200 -399 and read. through the sections on placards, drivers, and hazardous materials but comparison chart that listed the new divisions compared to could find no reference to the old "A B C" signs except a Ios that matter, the letter divisions. I could not, nor coulă any one elsa I am concerned that il the new placards are the only referende the validity of the older signs. the wrong message to the driver and could result in the ones authorized this question, on NJ's Hazmat test, Will send improper placard being used, further confusing younger amergency response personnel. rags. and rightly so. The driver should be given clear and The penalties are pretty severe for violations of hazmat personnel in my unit for their hazmat endorsement on their donoise instruction in this area. I teach hazmat • military license, Il I can't reference it how can I responsibly teaoh it ? ....#

Page 3-- SENT BYiXerox Telecopier 7021 ; 8-28-87 ; 9:20 ¡SPECIAL SERVICES DIV- 202 366 7342:# 3 I would appreciate if any one in your office could at • hat governs which placards (class 1) are authorized and what in the right direction or give me the statute the cut off date is (was). I apologize for any inconvenience this Inguiry may have caused and thank you in advande for your assistance. Please and any zeply to me at the address below. •• sincerely; Patrick G. 298 Mendham Rd. Kruger Morristown, N.J. 07960 -4805#