Guidanceguidance
99-0305
U.S. Department of Transportation — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research99-0305
Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research and Special Programs Administration DEC 9 1999 Mr. John D. Steinhoff Ref. No. 99-0305 U.s. Department of Transportation Office of Motor Carrier Safety City Crescent Building, Suite 4000 10 S. Howard Street Baltimore, MD 21201 Dear Mr. Steinhoff: •This is in response to your letter dated November 2, 1999, Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). regarding the proper shipping description for gas oil under the Specifically, you asked which of the following are proper shipping descriptions for gas oil: (1) Gas oil, 3, UN1202, III (2) Gas oil, Combustible liquid, UN1202, III (3) Gas oil, 3, Combustible liquid, UN1202, III (4) Combustible liquid, n.o.s., (Gas oil), UN1202, III Description (1) is correct. The proper shipping description for gas oil specified in the Hazardous Materials Table (HMT; $ 172.101) is "Gas oil, 3, UN1202, PG III." Description (2) is appropriate if the gas oil is reclassed as a combustible liquid in accordance with § 173.150 (f) • When a material is reclassed in accordance with $ 173.150 (f), each reference to Class 3 is modified to read "Combustible liquid" (§ 172.101 (d) (4)) . Description (3) is incorrect. Two hazard classes have been identified; Hazard class 3 (Flammable liquid) and Combustible • liquid. subsidiary class name, subsidiary class or division number While $ 172.202(a)(2) allows shippers to enter a following the numerical hazard . class, combustible liquid can not be a subsidiary of a flammable liquid. Description (4) is also 172.101 (g) 990305#
Page 2incorrect. Section 172.101 (d) (4) allows the hazard class to be modified from "3" to "Combustible liquid," but does not authorize modification of the proper shipping name. In addition, UN1202 is not the correct identification number for the proper shipping name "Combustible liquid, n.o.s." I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards#
Page 3BAH U.S. DEPARTMENT OF TRANSPORTATION $172.101 G) 1O S. Howard Street Gas Oil Baltimore, MD 21201 November 2, 1999 99-0305 IN REPLY REFER TO OMCS-EA Mr. Edward T. Mazzullo, Director Office of Hazardous Materials Standards Research & Special Programs Administration 400 7" Street, S. W., Room 8102 Washington, DC 20590 Dear Mr. Mazzullo: Attached, is a request for interpretation of the Hazardous Materials Regulations, which was sent to me by Senior Trooper Tod Williams, from the Texas Department of Public Safety. Specifically, Trooper Williams is seeking guidance on what would be the proper basic description of Gas Oil? The following are examples of what the folks in the field have been seeing on shipping papers for this product: Gas oil, 3, UN1202, II (As shown in the HM table) 2. Gas oil, combustible liquid, UN1202, III (Per 173.150(b) & 172.101(d)(4)) 3. Gas oil, 3, combustible liquid, UN1202, III (Per 172.202(a)(2)) 4. Combustible liquid n.o.s.(Gas oil), UN1202, III Please review Trooper Williams' request for interpretation and, the 4 examples above, and provide us with a written response as to what would be a proper or acceptable basic description for this product. Sincerely, John D/Steinhot / Operations Manager Office of Motor Carrier Safety Cc: Senior Trooper Tod Williams#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.