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Interpretation Response #08-0059 ([The Fertilizer Institute] [Ms. Pam Guffain])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Fertilizer Institute

Individual Name: Ms. Pam Guffain

Location State: DC Country: US

View the Interpretation Document

Response text:

July 29, 2008




Ms. Pam Guffain

Vice President, Member Services

The Fertilizer Institute

820 First Street, N.E. Suite 430

Washington, D.C. 20002

Ref. No.: 08-0059

Dear Ms. Guffain:

This responds to your letter regarding the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Anhydrous Ammonia shipped from Canada to the United States. Specifically, you ask if the placard required under Canada"s Transportation of Dangerous Goods (TDG) Regulations is acceptable when shipping Anhydrous Ammonia from Canada into the United States by highway or rail.

The answer is yes. Shipments of Anhydrous Ammonia prepared in accordance with the TDG Regulations are not required to be labeled or placarded with POISON INHALATION HAZARD or POISON GAS labels or placards (See §171.23(b)(10)(iv)). Thus, a package containing "Anhydrous Ammonia" shipped to the United States from Canada by motor carrier or rail car may be labeled or placarded in accordance with the TDG Regulations.

Special Provision "13", in § 172.102, specifies that for "Anhydrous ammonia," the words "Inhalation Hazard" must be entered on each shipping paper in association with the shipping description, and each non-bulk package must be marked ""INHALATION HAZARD" in association with the proper shipping name and identification number. Bulk packages must be marked on two opposing sides with the words "INHALATION HAZARD". The size of the marking on bulk packages must conform to § 172.302(b).

For your information, Amendment 6 of the TDG Regulations was published in the Canada Gazette, Part I, on September 30, 2006. The new subsection 4.18(5) requires that one of the following placards must be displayed when UN1005, ANHYDROUS AMMONIA, is contained in a large means of containment:

" Until August 31, 2008, the Class 2.2, Class 2.3 or the new Anhydrous Ammonia placard (see the Appendix to Part 4 of the TDG Regulations);

" After August 31, 2008, the Class 2.3 placard or the new Anhydrous Ammonia placard; and

" On at least two sides, the words "Anhydrous Ammonia, Inhalation Hazard" on a contrasting background in letters with a width of at least 6mm and a height of at least 50 mm when the Anhydrous Ammonia placard is displayed on it.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.

Sincerely,



Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards



171.23(b)(10)(iv), 172.102 SP13, 172.302(b)

Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
172.102 Special provisions
172.302 General marking requirements for bulk packagings.