July 18, 2017
By:
Walter G. Wright
Category:
Arkansas Environmental, Energy, and Water Law
Arkansas Environmental, Energy, and Water Law
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The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) clarified in a June 20th letter the Hazardous Materials Regulations (“HMR”) applicable to marketing and placarding of multi-compartment cargo tanks.
The PHMSA letter was in response to a December 12, 2016, query from AECOM.
AECOM described a scenario involving:
- A four compartment cargo tank containing two different hazardous materials
- Compartments 1 and 2 contained UN1760, Corrosive liquid n.o.s.
- Compartments 3 and 4 contained UN3264, Corrosive liquid, acidic, inorganic, n.o.s.
- The sides of each of the four compartments are placarded with a Class 8(corrosive) placard and marked with the applicable identification number for the hazardous material contained within.
AECOM asked whether the HMR:
. . . permit the display of one Class 8 (UN1760) placard and one Class 8(UN3264) placard when placarding the front and rear of the multi-compartment cargo tank if those two placards and identification numbers are representative of the materials contained in the cargo tank compartments.
PHMSA responds that:
. . . The HMR permit for the display you describe, provided the front and rear placards represent the two different substances contained in the four compartments of the cargo tank. It is not necessary to display all four placards on the front and rear of the cargo tank under these circumstances.
A copy of the letter can be downloaded here.
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