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Interpretation Response #18-0096

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

Interpretation Response Details

Response Publish Date:

Company Name: HOMENERGY Services, Inc

Individual Name: Dan Reilly

Location State: NY Country: US

View the Interpretation Document

Response text:

January 29, 2019

Dan Reilly
HOMENERGY Services, Inc.
33 Depot Street, Suite 1
Saranac Lake, NY  12983

Reference No. 18-0096

Dear Mr. Reilly:

This letter is in response to your June 29, 2018, email and August 21, 2018, phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding.  Specifically, you indicate that you transport diesel fuel, heating oil, kerosene, and gasoline in multi-compartment cargo tanks.

We have paraphrased and answered your questions as follows:

Q1. You ask if it is appropriate to display the identification number “1993” on the outside of the cargo tank motor vehicle when transporting only diesel fuel.
 
A1. The answer is yes.  As prescribed in § 172.302(a), no person may offer for transportation or transport a hazardous material in a bulk packaging unless the packaging is marked, as required by § 172.332, with the identification number specified for the material in the § 172.101 Hazardous Materials Table (HMT).  Therefore, if you are transporting diesel fuel domestically as “NA1993, Diesel fuel, Combustible, III,” it is appropriate to display “1993” on the outside of the cargo tank motor vehicle in accordance with § 172.332. 

 Furthermore, while not explicitly prohibited by the HMR, it is recommended that in order to avoid confusion and frustration in transportation, the identification number on the shipping paper and package marking should be consistent (i.e., the shipping paper should not list “UN1202, Diesel fuel, Combustible, III,” while “1993” is displayed as the identification number on the outside of the cargo tank motor vehicle).
 
Q2. You ask if it is appropriate to display the identification number “1993” on the outside of the cargo tank motor vehicle when transporting only heating oil.
 
A2. If you are transporting heating oil domestically as “NA1993, Fuel oil, Combustible, III,” the answer is yes.  See A1.

Q3. You ask if it is appropriate to display the identification number “1223” on the outside of the cargo tank motor vehicle when transporting only kerosene.
 
A3. The answer is yes.  Kerosene, described as “UN1223, Kerosene, 3, III,” must display “1223” on the outside of the cargo tank motor vehicle in accordance with § 172.332.

Q4. When transporting more than one of the materials identified in your request, you ask which identification number must be displayed on the outside of the cargo tank motor vehicle.

A4. In accordance with § 172.336(c), for the specific materials identified in your request, when a cargo tank contains more than one petroleum distillate fuel, it needs only to display the identification number of the liquid petroleum distillate fuel with the lowest flashpoint.  For example, if the cargo tank is transporting “NA1993, Diesel fuel, Combustible, III” and “UN1203, Gasoline, 3, II,” it needs to display UN1203 only, as gasoline has a lower flashpoint than diesel fuel.  Please note that if only one petroleum distillate fuel is being transported in the cargo tank, the identification number for that petroleum distillate fuel must be displayed.
 
I hope this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development
Standards and Rulemaking Division

172.332, 172.101, 172.336(c)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.302 General marking requirements for bulk packagings.
172.332 Identification number markings
172.336 Identification numbers; special provisions