# Liquid Transport Corporation — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 98-0425
- **title:** Liquid Transport Corporation — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1998-05-01
- **effective on:** Not available
- **summary:** 98-0425 response to Liquid Transport Corporation concerning 172.602, 172.606.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-98-0425.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-98-0425.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-98-0425
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980425.pdf
**body:**

<<<PAGE 1>>>

=.
=-..
U.S. Department
of Transportation
Washington, D C
400 Seventh Street, SW
20590
Special Programs
Research and
Administration
MAY - | 1998
Mr. Frank L. Boone
Liquid Transport Corporation
6171 W 300 N
Greenfield, IN 46140
Dear Mir. Boone:
This is in response to your letter regarding the requirements for carrier notification and
information contact that apply to an unattended motor vehicle disconnected from its motive
power, and a definition of "spotting" under the Hazardous Materials Regulations (HMR; 49
inconvenience.
CFR Parts 171-180). I apologize for the delay in responding and hope it has not caused any
A final rule was published in the Federal Register on July 22, 1997 [62 FR 39398] which
made corrections and responded to petitions for reconsideration of certain aspects of the
January 8, 1997 final rule [Docket HM-206; 62 FR 1217; effective October 1, 1998], entitled
"Improvements to Hazardous Materials Identification Systems." On April 1, 1997, a final rule
[63 FR 16070] was published making technical amendments and editorial corrections in
response to several petitions for reconsideration and an appeal of certain aspects of the
July 22, 1997 final rule.
The term "spotting" is not defined in the HMR. The requirements in § 172.606(b) specify that
if a highway transport vehicle contains hazardous material for which a shipping paper is
requirea and the vehicle is separated from its motive power and parked at a location other
than a consignee's, consignor's, or a facility subject to the provisions of § 172.602(c)(2),
such as a carrier's terminal, marine terminal, or cleaning facility, the carrier must:
1)
Mark the telephone number of the motor carrier on the exterior of the transport
vehicle, or on a label, tag, or sign attached to the vehicle, at the brake hose or
electrical connection; or
2)
Have the shipping paper and emergency response information readily available on the
transport vehicle; unless
An unattended motor vehicle separated from its motive power is marked with the
identification number of the hazardous material loaded therein (see § 172.602(c)).
:

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Therefore, the carrier information contact requirements apply to an unattended motor vehicle
separated from its motive power and dropped or parked at a location, such as a motel or truck
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Demy Bellings
•
•
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
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engrum fiste
File HM 204
SC:
liquid transport corp
March 7, 1997
RSPA
U.S. Department of Transportation
Office of Motor Carrier standards
Washington,
400 Seventh St., S.W.
D.C.
Dear Sirs:
AM-206
We would appreciate it if you could offer clarification in
the form of
definition of spotting. The requirements of HM aRe affect
an interpretation concerning H#2eton the
consignee,
equipment spotted at locations other than shipper,
product and contact information
or carrier facilities. The requirement
to have
be less of a burden if
we have a true understanding of
on or in the unit if spotted
units dropped at tank washes for tinnings defied.
dropped
as detined, include
definition include service facilities where
dropped for minor repairs, adjustments, etc.?
units may be
convenience.
Please provide an interpretation at your earliest
Sincerely,
Vice President,
Frank L.
Safety and Compliance
lift message
cc/Lanny Wilhelm
Keith Lewis
John Miskimen
Safety file
Dennis Cherry
An ano Company
317) 894-2501
reenfield, IN 46141
Fax: (317) 894-8259

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MAY
son
5 1935
Mx. E. A. Altemos
Technical
Advisor
Winston & Strawn
Washington, D.C.
1400 I Street, N.W.
20005-3502
Dear Mr. Altemos:
inconvenience it may have caused.
I apologize for
the delay in responding and regret any
Your understanding is correct.
cargo, a motor carrier must ensure that an emergency response telephone
Before accepting a hazardous materials
number appears on a shipping paper as required in 49 CFR 172. 604(a) (3).
response telephone number meets the remaining requirements of § 172.604.
However, a motor carrier is not required to verify that the emergency
Che shipper is responsible for ensuring that the emergency
elephone number is operative and meets the requirements in § 172.604(b).
response
I hope this information has been helpful. Please do not hesitate to
contact us 1t we can be of further assistance.
Sincerely,
Delmer F. Billings
Chief,
Office
Regulations Development
of Hazardous Materials Standards
File:
GWYNN: at: DHM-11: 64488:1/4/95
181/172.600
SC:
399,
290
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<<<PAGE 5>>>

U.S. Department
of Transportation
Here be ir
"Soverth crop."
special Programs
Research and
Administration
MAY
5 1035
Technical Advisor
Mr. E. A. Altemos
Winston & Strawn
Washington, D.C.
1400 L Street, N.W.
20005-3502
Dear Mr. Altemos:
This is in response to your letter asking if a carrier must verify that a
hazardous materials shipper
telephone monitoring company's telephone number indicated on a shipping
registered with the emergency response
inconvenience it may have caused.
I apologize for the
•delay in responding
and regret any
Your understanding is correct.
cargo, a motor carrier must ensure that an emergency response telephone
Before accepting a hazardous materials
number appears on a shipping paper as required in 49 CFR 172.604(a) (3).
However, a motor carrier is not required to verify that the emergency
response telephone number meets the remaining requirements of § 172.604.
The shipper is responsible for ensuring that the emergency response
telephone number is operative and meets the requirements in § 172.604(b).
I hope this information
contact us if we can be of further assistance.
has been helpful.
Please do not hesitate to
Sincerely,
Ishman Hill's
Delmer F. Billings
Office
Chief,
Regulations Development
of Hazardous Materitis Standards
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