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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0203 ([Minnesota Department of Transportation] [Mr. Michael Ritchie])

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

Interpretation Response Details

Response Publish Date:

Company Name: Minnesota Department of Transportation

Individual Name: Mr. Michael Ritchie

Location State: MN Country: US

View the Interpretation Document

Response text:

Jan 31, 2007

 

Mr. Michael Ritchie                 Reference No. 06-0203
Hazardous Materials Specialist
Minnesota Department of Transportation
395 John Ireland Boulevard
Mail Stop 460, Room 121
St. Paul, MN 55155

Dear Mr. Ritchie:

This is in response to your August 29, 2006 letter requesting clarification of the marking requirements for a compartmented cargo tank under the Hazardous Materials Regulations (1-IMR; 49 CFR Parts 17 1-180). You state that most bulk transport companies in your r’ display identification numbers on placards and do not utilize orange panels or white square-on-point configurations. Therefore, this letter addresses the display of identification numbers on hazard warning placards.

Your questions pertain to a cargo tank equipped with four compartments. Compartment 1 contains “Gasoline, UN1203”; compartment #2 contains “Diesel fuel, NA1993”; compartment #3 contains “Denatured alcohol, NA 1987”; and compartment #4 contains ‘Gasoline, UN 1203”. Provided no exceptions are utilized, a compartmented cargo tank. containing multiple Class 3 materials must be marked with the appropriate identification number for each different hazardous material on both sides and both ends in accordance with § 172.332. In this case, a Class 3 placard displaying UN number 1203, a Class 3 placard displaying NA number 1993, and a Class 3 placard displaying NA number 1987 must appear on both sides and both ends of the cargo tank. The placards displaying identification numbers do not have to appear in any particular order.

Q1.      May the compartmented cargo tank utilize the exceptions provided in both 172.336(c)(1) and 172.336(c)(4)? Under this scenario, the compartmented cargo tank would display on each side a single Class 3 placard with UN number 1203 to identify the contents of compartments #1 and #2; a single Class 3 placard with NA number 1987 to identify the contents of compartment #3; and a single Class 3 placard displaying UN number 1203 to identify the contents of compartment #4. A single Class 3 placard without identification numbers would be displayed on the front and the rear of the cargo tank

Al.        The answer is yes. In accordance with § 172.336(c)(1), a compartmented cargo tank containing hazardous materials with different identification numbers is excepted from the requirement to display identification numbers on the front and rear (i.e., ends) of
the cargo tank when the identification numbers are displayed on the sides of the tank in the same sequence as the compartments containing the materials they identify. Moreover, in accordance with § 172.336(c)(4), identification numbers are not required for each of the different petroleum distillate fuels in a compartmented cargo tank if the identification number for the liquid petroleum distillate fuel having the lowest flash point is displayed.

Q2.      May the compartmented cargo tank utilize the exception provided in
§ 172.336(c)(4)? Under this scenario, the cargo tank would display on each side one Class 3 placard with UN number 1203 and one Class 3 placard with NA number 1987.

A2.      Again, the answer is yes. In accordance with § 172.336(c)(4), identification numbers are not required for each of the different petroleum distillate fuels in a compartmented cargo tank if the identification number for the petroleum distillate fuel with the lowest flash point is displayed. However, because the markings are riot displayed on the sides of the cargo tank in the same sequence as the compartments containing the materials they identify, additional hazard warning placards with identification numbers representing each hazardous material must be displayed on the ends of the cargo tank.

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

Sincerely,

 

Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards

173.336 (c)

Regulation Sections

Section Subject
173.336 Nitrogen dioxide, liquefied, or dinitrogen tetroxide, liquefied