I wonder if you fine folks could help me. My mother works for a major oil company. She was telling me that the company owns a fleet of tank cars. She was telling me that where she works, they are making tags that are placed on the placards. The way she explained it, the tag tells what is in the car instead of the number that is already on the placard.
Is this a new FRA rule or a company rule? It sounds like a good idea.
Not sure what this is about. The UN numbers on the placards are universally understood by emergency responders, so it’s not clear to me what value the “tags” (whatever they are) add, or whether responders would even pay much attention to them. They would look at the placards and the manifest.
From your description, it sounds like the descriptions are replacing the placard number. If so, it would have to be a change in federal law. The placard numbers are required by Chapter 49 of the Code of Federal Regulations. Unless Canada and Mexico have changed their laws, it would create problems with haz-mat shipments going across borders.
If the descriptions are replacing the numbers, that is bad. In the event of a release, you want to be able to read the placard as far away as possible, The letter sizes of the descriptions would have to be smaller than the current placard numbers. This means you will have to get closer to read the placards, or get more powerful binoculars.
Maybe that’s not for the emergency responders, but just to help make sure that the loading plant’s people match up the right number code with the product name that they likely know better, or are more familiar with - a quality control measure. Or even to facilitate placard inventory control - keeping enough on hand for each product type.
Or - as we have seen here from time to time - one of the number codes can cover several different products. This would provide supplemental information to narrow the possibilities down and be more precise. Yes, the responders would have to get closer - but at least the information would be available.
Any other thoughts ? Do the DOT regs preclude or prohibit such supplemental information ?
But pretty useless if the tank is laying on its side leaking like a sieve!
This sounds more plausible. As of yet nothing has come down the pipe about changes to HAZMAT rules.
Maybe go back and ask Mom for a fuller explanation?
[tup][tup]
Good Idea! Ms. Mookie!
Could this be an individual and a local solution for a local issue? Possibly an extention of the practice of stenciling on some cars the product contained within for cars in an assigned service?
It appears that that the name of the material is already permitted, per the following, from - http://edocket.access.gpo.gov/cfr_2009/octqtr/49cfr172.332.htm
[emphasis added - PDN]
[Code of Federal Regulations]
[Title 49, Volume 2]
[Revised as of October 1, 2009]
From the U.S. Government Printing Office via GPO Access
[CITE: 49CFR172.332]
[Page 351-352]
TITLE 49–TRANSPORTATION
CHAPTER I–PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION, DEPARTMENT OF TRANSPORTATION
PART 172_HAZARDOUS MATERIALS TABLE, SPECIAL PROVISIONS, HAZARDOUS MATERIALS COMMUNICATIONS, EMERGENCY RESPONSE INFORMATION, TRAINING
Subpart D_Marking
Sec. 172.332 Identification number markings.
(a) General. When required by Sec. 172.301, Sec. 172.302, Sec.
172.313, Sec. 172.326, Sec. 172.328, Sec. 172.330, or Sec. 172.331,
identification number markings must be displayed on orange panels or
placards as specified in this section, or on white square-on-point
configurations as prescribed in Sec. 172.336(b).
(b) Orange panels. Display of an identification number on an orange
panel shall be in conformance with the following:
(1) The orange panel must be 160 mm (6.3 inches) high by 400 mm
(15.7 inches) wide with a 15 mm (0.6 inches) black outer border. The
identification number shall be displayed in 100 mm (3.9 inches) black
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