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Interpretation Response #05-0252 ([Uwchalan Township Police Department] [CPL F. Allen Mauger, Jr.])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Uwchalan Township Police Department

Individual Name: CPL F. Allen Mauger, Jr.

Location State: PA Country: US

View the Interpretation Document

Response text:

Oct 28, 2005

 

CPL F. Allen Mauger, Jr.                       Reference No. 05-0252
Special Operations/Traffic Safety
Uwchalan Township Police Department
717 N. Ship Road
Exton, PA 19341-1946

Dear CPL Mauger:

This is in response to your September 30, 2005 letter and subsequent telephone conversation with Ben Supko of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). First, you ask if a cargo tank motor vehicle transporting fuel oil may be placarded on the sides and rear with combustible placards marked with “UN1993” and a “fuel oil” placard on the front. Second, you ask if CORROSIVE placards with a white panel area in the center but no identification number marked in the white panel area are acceptable for a non.-bulk shipment.

A cargo tank containing fuel oil, classed as a combustible liquid, must display COMBUSTIBLE placards. In accordance with § 172.544(c), the placards may be modified to read “FUEL OIL” rather than “COMBUSTIBLE.” Therefore, the placement of a COMBUSTIBLE placard with the words “FUEL OIL” on the front of the cargo tank is not a violation of the HMR. However, § 172.302(a) requires the identification number for the material to be marked on each side and each end of a packaging with a capacity of 3,785 L (1,000 gallons) or more. Since the COMBUSTIBLE placard with the words “FUEL OIL” is displayed on the front of the cargo tank and the identification number is not marked on an orange panel or white square-on-point configuration (see § 172.332(b)), the marking requirements in § 172.302(a) are not fulfilled.

The CORROSIVE placard must conform to the requirements in § 172.558, except that it maybe modified to display the identification number of the material (see § 172.332(c)), or modified by removing the word “CORROSIVE” (see § 172.5 19(b)(3)). The placard you describe, a CORROSIVE placard with a blank white panel area in the center, does not fulfill the requirements of § 172.558 or the exceptions mentioned above.

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

Sincerely,

 

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

172.504

Regulation Sections

Section Subject
172.504 General placarding requirements