{"operation":"document","citation":"99-0193","title":"Mr. Gerald L. Blase — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-08-13","effective_on":null,"summary":"99-0193 concerning 172.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0193.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0193.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0193","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990193.pdf","body":"<<<PAGE 1>>>\n\n•\nof Transportation\nUS. Department\nVas singion, D.C. 15.5\n20590\nResearch and\nAdministration\nspecial Programs\nAUG 1 3 1999\nMr. Gerald L. Blase\nRef. No. 99-0193\nManager, Asplundh Railroad Division\n708 Blair Mill Road\nWillow Grove, PA 19090-1784\nDear Mr. Blase:\nThis is in response to your letter dated July 20, 1999, requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR 171-180) as they relate to the transportation of Class 9\nhazardous materials. Specifically, you ask whether a CLASS 9 placard is required to be.\ndisplayed for domestic transportation.\nAs provided by § 172.504 (f)(9), the answer is no; a CLASS 9 placard is not required for\ndomestic transportation. This exclusion from the CLASS 9 placarding requirement applies to\nboth non-bulk and bulk packages. Each non-bulk package must be marked with the proper\nshipping name and identification (ID) number as provided for by § 172.301 and must display a\nCLASS 9 Label as provided by § 172.400. In addition, if a non-bulk package contains a\nhazardous substance, the letters \"RQ\" must be marked on the package in association with the\nproper shipping name as provided for by § 172.324. Each bulk package must be marked on each\nside and each end with the appropriate ID number displayed on a placard, orange panel, or when\nappropriate a white square-on-point configuration. However, if a carrier chooses to display\nCLASS 9 placards on a bulk package, the ID number may be displayed on the placard or orange\npanel as provided by § 172.332(c).\nI hope this information is helpful. Should you have further questions, please contact us.\nSincerely,\nHatte a mither\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Standards\ncc: West Virginia Public Service Commission\n8136\n172.504\n990193\n\n<<<PAGE 2>>>\n\nASPLUNDE\nBelts\nASPLUNDH RAILROAD DIVISION\n5172.504\n708 BLAIR MILL ROAD, WILLOW GROVE, PA 19090-1784 • AREA CODE 215 • TELEPHONE 784-4206 • FAX 784-1366\n99-0193\nTuesday, July 20, 1999\nUS Dept. Of Transportation\nResources & Special Projects Adm.\nA00 Ha. Mat. Standards DHM10\nWashington, DC\nStreet\n20590\nDear Sir/Madam:\nsuggests I present my problem to you for a determination to be made on\nIn discussions with Mr. Raymond I. LaMagdelaine of your office, he\nthe facts,\nand a written statement issued.\nSome of the products which we transport are listed in APPENDIX A and\nclassed as \"Other Regulated Substances\" which do not require placards.\nHowever ID numbers may apply to certain shipments, only if the \"RQ\"..\nsingle container.\n(in our case 100 lb.) of the active is ingredient is packaged in a\nbulk containers.\nNone of these products are transported by us in\nIt is our understanding of the regulations,\nedition) section 172.504 (f) (9).\nthe Identification number in a white.\n49. CFR (October: 1, 1998\nmarking for this shipment, and that a CLASS 9 Placard is NOT REQUIRED : C:\nsquare on point display configuration is an acceptable and PROPER\nFOR DOMESTIC SHIPMENTS.\n188S.X33\nOur drivers are being cited, and in one instance | see Citation\nenclosed)\nthe vehicle was placed \"Out of Service\" for not having a\n• 0% 00:\nClass 9 Placard displayed ( the ID # was properly displayed) and\nClass 9. The Citation also lists not having W.Va. Hazardous Material.\nremained \"out of service\" until the driver switched the Placard to a =\nCredentials which are required for \"Bulk Carriers of Haz. Mats. of\n3,500 gal or 468 cu.ft. in a single container (which is a State issue)\nIs my understanding\nregulations correct?\nand interpretations of the Class 9 Placard\nso that my drivers will have it available when they are challenged on\nCan you please send me a written determination.\nthis issue. Also, is it possible to remove this particular out of\nvehicle\nservice violation\nthat was properly marked\n0101328 since we WERE moving a\n177.823A)\nI appreciate your assistance in this matter.\nsincerely!\nGrabel Blase.\nGerald L. Blase\nManager Asplundh Railroad Division\nenclosure: WV report # 00227965","truncated":false,"body_characters":3998}