CARGO TANK PLACARDING

Energy Marketers should take note that long standing placarding practices for cargo tanks vehicles were reinterpreted a few years ago by the U.S. DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA). Many state motor carrier authorities conducting roadside inspections have been slow to implement the federal changes. As a result, uneven enforcement has created regulatory uncertainty and unnecessary fines for improper placarding.

PHMSA published an interpretive letter regarding when placards can be marked with the identification number of the product with the lowest flashpoint in a split load delivery. This is important because energy marketers routinely placard straight and split loads of diesel fuel, kerosene or heating oil with the “1203” identification number for gasoline so that the driver is not required to change placards between delivery runs of different products. The same practice is followed when using the “1223” kerosene placard for split loads of diesel fuel and heating oil. This practice was allowed as an exception under the federal placarding rules for many years and is widely used across the industry. However, the recent PHMSA interpretation of the exception limits placarding to the lowest flashpoint to split loads only. Moreover, in order to placard to the lowest flashpoint, at least one compartment in the split load must contain the product indicated on the placard.

PLACARDING FOR STRAIGHT LOADS

Straight load shipments are those that contain the same product in all compartments of the same cargo tank vehicle. Straight loads of gasoline may be marked with the cargo tank placard identification number “UN1203”. Straight loads of diesel fuel may be marked with either the cargo tank placard identification number “NA1993” or “UN1202”. Straight loads of heating oil may be marked with the cargo tank identification number “NA1993”. If there is no gasoline in a compartment of a cargo tank then the “1203 placard cannot be used. The “1203” placard can no longer be used for straight loads of diesel fuel or heating oil. The same is true for heating oil transported under the “1223” placard for kerosene. If no compartment onboard contains kerosene, then the “1223” placard cannot be used.

PLACARDING FOR SPLIT LOADS

Split load shipments are those that contain different products in separate compartments of the same cargo tank vehicle. If gasoline and either heating oil, kerosene or diesel fuel (or both) are shipped in separate compartments of the same cargo tank shipment, then the placard for the product with the lowest flashpoint may be used - which in this case is “1203” for gasoline.

PHMSA CLARIFICATIONS

EMA obtained the following clarifications from PHMSA which will help energy marketers more easily comply with marking requirements for placards:

Although shipments of gasoline and heating oil in cargo tank vehicles must be placarded, those placards are not required to be marked with either “1203” or “1993” ID numbers respectively. Placards may be marked instead with the words “GASOLINE” or “FUEL OIL” as appropriate. Diesel fuel must be shipped under either “1202” or “1993”. PHMSA is not discontinuing the use of the “Gasoline” or “Fuel Oil” placards.

PHMSA only allows placards to be marked to the lowest flashpoint of the product in any compartment of a split load transported different compartments of the same a cargo tank vehicle. There can be no placarding to the lowest flashpoint when all compartments contain the same product.

PHMSA allows a cargo tank vehicle containing both gasoline and diesel fuel/heating oil to be marked with the ID number (or similar approved marking as discussed above) for gasoline which has the lowest flash point. Split loads of both gasoline and diesel fuel/heating oil may be marked with the “1203” ID number for gasoline. An additional placard marking such as “1993” for diesel fuel or heating oil is not required for split loads.

PHMSA no longer allows straight loads of diesel fuel, kerosene or heating oil to be marked with the “1203” ID number for gasoline (or any other of the gasoline markings discussed above). If there is no gasoline in any compartment of the cargo tank, then the “1203 number may not be used on the placard. Instead, the placard must display any of the approved markings - such as “1993” or “1202” for heating oil.

PHMSA no longer allows straight loads of heating oil or diesel fuel to be marked with the “1223” placard for kerosene. If there is no kerosene onboard, the 1223 placard cannot be used. Instead, the placard must display the approved markings - such as “1993” or “1202” for heating oil or diesel fuel.

PHMSA considers a compartment “empty” when it is cleaned of product and purged of vapors. Empty compartments are not required to be placarded. A compartment containing the residue of any hazardous material must be placarded and marked. Therefore, a three-compartment cargo tank with 1 compartment of heating oil, 1 compartment of diesel fuel and 1 compartment of gasoline residue may be placarded to the lowest flashpoint of gasoline for the whole load.

Left over product in piping connected to an “empty” compartment does not require the empty compartment to be placarded. Placard and marking requirements apply to cargo tank compartments and not hose or attached product lines.

PHMSA PLACARDING REGULATION

§172.336 Identification numbers; special provisions.

(b) Identification numbers, when required, must be displayed on either orange panels (see §172.332(b)) or on a plain white square-on-point display configuration having the same outside dimensions as a placard. In addition, for materials in hazard classes for which placards are specified and identification number displays are required, but for which identification numbers may not be displayed on the placards authorized for the material (see §172.334(a)), identification numbers must be displayed on orange panels or on the plain white square-on-point display configuration in association with the required placards. An identification number displayed on a white square-on-point display configuration is not considered to be a placard.

(1) The 100 mm (3.9 inch) by 215 mm (8.5 inches) area containing the identification number shall be located as prescribed by §172.332 (c)(1) and (c)(2) and may be outlined with a solid or dotted line border.