Interpretation Response #22-0008

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

Interpretation Response Details

Response Publish Date: 05/06/2022

Company Name: Public Utilities Commission of Ohio

Individual Name: Tom Forbes

Location State: OH Country: US

View the Interpretation Document

Response text:

May 6, 2022

Tom Forbes
Chief, Motor Carrier Enforcement Division
Public Utilities Commission of Ohio
180 E. Broad Street
Suite 421
Columbus, OH  43215

Reference No. 22-0008

Dear Mr. Forbes:

This letter is in response to your February 4, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the domestic transportation of "UN1978, Propane, 2.1" as "UN1075, Propane, 2.1" in accordance with Special Provision (SP) 19.

We have paraphrased and answered your questions as follows:

Q1. You ask whether transporting “UN1978, Propane, 2.1" as "UN1075, Propane, 2.1" in accordance with SP 19 requires a person to indicate on a shipping paper "NONCORROSIVE" or "NONCOR," "NOT FOR Q and T TANKS," or would this only be applicable when “UN1075” is shipped as liquefied petroleum gas.

A1. When using the identification number "UN1075" in accordance with SP 19 or otherwise, the marking requirements of § 172.203(h)(2) are applicable. Therefore, shipping papers for applicable packagings must include the words "NONCORROSIVE", "NONCOR", or "NOT FOR Q and T TANKS"—as appropriate—in accordance with § 172.203(h)(2).

Q2. You ask whether transporting "UN1978, Propane, 2.1" as "UN1075, Propane, 2.1" in accordance with SP 19 requires a person to mark the cargo tank as propane in accordance with § 172.328(b) to match the shipping paper or does the cargo tank have to be marked as liquefied petroleum gas.

A2. When transporting "UN1075, Propane, 2.1" domestically in accordance with SP 19, a person is permitted to mark a cargo tank as either propane or liquefied petroleum gas, provided that the identification number is consistent on package markings, shipping papers, and emergency response information as required by SP 19.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.203(h)(2), 172.328(b)

Regulation Sections