Interpretation Response #05-0189

Interpretation Response Details

Oct 28, 2005

Mr. Paul Goodwin                      Reference No. 05-0189
Transportation Manager
NASA-White Sands Test Facility
12600 NASA Road
Las Cruces, NM 88012

Dear Mr. Goodwin:

This responds to your July 28, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a closed transport vehicle containing ten 650 pound cylinders of methylhydrazine, a Hazard Zone A poisonous by inhalation (PIE) material, must be placarded with the POISON INHALATION HAZARD placard provided in § 172.555. In addition, you ask if the transport vehicle must be marked in accordance with § 172.313.

As provided in § 172.504(e), a transport vehicle containing any amount of Division 6.1, Hazard Zone A or B material (i.e., methylhydrazine) must display the placards depicted in § 172.555 on each side and each end. In addition, because your transport vehicle contains more than 2,205 pounds of methylhydrazine, it must be marked on each side and each end with “UN 1244” (172.313(c)). The identification number must be displayed on orange panels or placards as specified in § 172.332, or on white square-on-point configurations as prescribed in § 172.336(b).

Also note that § 172.313(a) requires the words “Inhalation Hazard’ to be marked in association with required labels, placards, and shipping name when appropriate. This requirement applies to the package itself. Therefore, the words “Inhalation Hazard” must be marked in association with the label on non-bulk packagings; bulk packaging such as a cargo tank or rail tank car must be marked with the words “Inhalation Hazard’ in association with the placard on two opposing sides. When the words “Inhalation Hazard” appear on the label or placard, this marking is not required

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A. Gale
Chief, Standard Development
Office of Hazardous Materials Standards

172.504, 172.555, 172.333

Regulation Sections