Interpretation Response #06-0213

Interpretation Response Details

Jan 25, 2007

Ms. Robin J. Eddy Bolte                Reference No. 06-0213
Allied Universal Corporation
3901 NW 115 Avenue
Miami, FL 33178

Dear Ms. Bolte:

This is in response to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the marking, labeling and placarding requirements applicable to transportation by highway of "Chlorine," 2.3, 8 UN1017 and "Sulfur dioxide," 2.3, 8, UN1079 in 3A and 3AA cylinders and in multi-unit tank car motor vehicles. "Chlorine," UN is poisonous by inhalation in Hazard Zone B, and "Sulfur dioxide," UN 1079 is poisonous by inhalation in Hazard Zone C.  You ask whether the scenarios presented below meet the requirements under the HMR, and whether the J-IMR requires the words "Inhalation Hazard" to be displayed on the package when it is displayed on the label. Your questions are paraphrased and answered below.

Q1a.    Cylinders containing "Chlorine," 2.3, 8, UN1017, Hazard Zone B, are transported by motor vehicle. The cylinder is affixed with a poison gas label or tag, no smaller than 4 inches on each side; the label includes the words "Inhalation Hazard." The label or tag includes the proper shipping name and UN identification number and the name and address of the distributor. In addition, the cylinders are affixed with a CORROSIVE label or tag to represent the subsidiary hazard of the material. Does this scenario conform to HMR requirements?

Ala.      Yes. Provided the labels conform to Subpart E of Part 172, they may b displayed on the cylinders. In addition, under § 172.400a(a)(1)(ii), you may label the cylinders in accordance with CGA C-7, Appendix A. Note that when the words "Inhalation Hazard" appear on a label, the wording is rot required on the package (see § 172.3 13(a)).

Q1b.    Cylinders containing "Chlorine," 2.3, 8, UNIO17, Hazard Zone B are transported in a motor vehicle that is placarded on each side and each end with POISON GAS placards. Allied chooses to display the identification number marking "UN1017" on the placards instead of the words "Inhalation Hazard." Does this scenario conform to the requirements in the HMR?

A1b.    If the words "Inhalation Hazard" do not appear on the placard, each chlorine cylinder must be marked with the words "inhalation Hazard." A transport vehicle that contains a poisonous material subject to the poison inhalation hazard shipping
description in §172.203(m)(2) must be placarded with, in this case, the POISON GAS placard. A transport vehicle or freight container containing a material poisonous by inhalation in non-bulk packages must be marked, on each side and each end with the identification number as specified in § 172.332 or § 172.336, subject to the provisions and limitations specified in §172.313(c).

Q2a.    A ton container (multi-unit tank car tank) containing "Chlorine," 2.3, 8, UN1017, Hazard Zone B, is transported by motor vehicle. The ton tank is affixed with a POISON GAS label or tag, no smaller than 4 inches on each side; the label includes the words "Inhalation Hazard." The label or tag includes the name and address of the distributor. The ton container is marked on two opposing sides with the proper shipping name, UN number, and the words "Poison Inhalation Hazard." The stenciled letters and numbers are 2 inches high. In addition, the ton container is affixed on both ends with a CORROSIVE label or tag to represent the subsidiary hazard of the material. Does this scenario conform to HMR requirements?

A2a.     Yes.

Q2b.    For the ton containers described in Q2a, the motor vehicle is placarded on all four sides with POISON GAS placards. On each placard the UN identification number is substituted for the words "inhalation hazard." Does this scenario conform to HMR requirements?

A2b.    Yes.

Q3.     Allied also ships sulfur dioxide in cylinders and multi-unit tank car tanks that are:
marked and labeled in the manner as described above for "Chlorine," except the ton container is dark green and the stenciled letters and numbers are white. Does this scenario conform to the HMR requirements?

A3.      See above responses.

I hope this information is helpful. Please contact this office if you need further assistance.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.400, 172.313(c), 172. Subpart F

Regulation Sections