Guidanceguidance
99-0262
Rootstown Office — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation DEC 22 1999 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration Ms. Carleen A. Ahrens Ref. No: 99-0262 • Level Propane Rootstown Office Post Office Box 226 Rootstown, OH 44272 Dear Ms. Ahrens: This is in response to your letter dated October 26, 1999, and subsequent phone conversations with Mr. Michael Johnsen of my staff concerning placarding requirements for your propane storage tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) • Propane storage tanks must be placarded on each side and each end as required in § 172.514. However, § 172.514 (c) provides an exception which allows labeling instead of placarding for certain portable tanks, DOT 106 and 110 multi-unit tank cars, IBCs and bulk packagings with a volumetric capacity of less than 18 cubic meters (640 cubic feet). Your tank is a bulk packaging which has a volumetric capacity of less than 18 cubic meters, thus eligible for this exception. I hope this satisfies your request. Sincerely, Velo Amn 7 Billio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.511 990262#
Page 2LEVEL PROPANE 1-800-6LEVEL1 Rootstown Office 1-330-325-8444 Rootstown, OH 44272 P. O. Box 226 FAX 1-330-325-8761 October 26, 1999 Department of Transportation Office of Hazardous Material & Safety Attn: Mike Johnsen 400 7ih Street, SW Washington, DC 20590 Dear Mr. Johnsen, Currently you have been working with us regarding placards vs. labeling requirements. Attached you will find our first letter of communication to your office for your reference. Per our telephone conversation, we have forwarded pictures of our service truck loaded with our tanks in question. Please call Ron LeMaster or myself at 800-653-8351 ext. 200, with any questions you may have. Thank you for your time in this matter. Sincerely, Carlend Chund ghem Carleen A. Ahrens Transportation Department Enclosures Propane and equipment for residential, commercial, agriculture and construction#
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