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from here to there: topics in transportation Steven CharleS hunt President, ShipMate, Inc. Proposed Rules Will Require Rulers The Notice of Proposed Rulemaking (NPRM), HM- must be marked in a size appropriate for the size of the 215L, published on Aug. 15, 2012 by the U.S. Depart- package. ment of Transportation’s (DOT) Pipeline & Hazardous PHMSA believes that, without a minimum size require- Materials Safety Administration (PHMSA), proposes ment for hazard communication, shippers may mark a number of amendments to the Hazardous Materials packages in a format that makes it very hard for first Regulations (HMR) in Title 49, Code of Federal Regula- responders to quickly identify the commodity associated tions, subchapter C. These changes will align several key with a particular package. Therefore, PHMSA proposes U.S. requirements with the latest editions of the United this minimum size marking for the identification number Nations Model Regulations on the Transport of Dan- to improve safety and to align the HMR with newly gerous Goods (17th revised edition), the International adopted requirements in the 17th Revised Edition of the Maritime Dangerous Goods Code (Amendment 36) and UN Model Regulations. the International Civil Aviation Organization’s Technical Instructions on the Safe Transport of Dangerous Goods New Vessel Stowage Requirements (2013-2014 edition). The proposed changes in the NPRM will also affect the stowage of aerosols aboard vessels. Currently, the Hazard- Minimum Package Marking Dimensions ous Materials Table (column 10B) lists stowage provi- Currently, the HMR specifies size requirements for UN sions 48, 87 and 126. These vessel stowage provisions are specification packaging markings (see 49 CFR §178.3(a) currently defined in 49 CFR 176.84 as: 48 – Stow “away (4)). UN specification packaging markings (e.g., UN/4G/ from” sources of heat; 87 – Stow “separated from” Class 1 Y10/S/12/USA/M1234) must have minimum height di- (explosives) except Division 1.4; and 126 – Segregation mensions of at least 12.0 mm (0.47 inches) for packaging same as for Class 9, miscellaneous hazardous materi- greater than 30 L (7.92 gallons) for liquids or 30 kg (66 als. Under the new (proposed) rules, the vessel stowage pounds) for solids. The HMR also specifies that an iden- provisions will be listed and defined as: 25 – Protected tification number, preceded by the letters ‘‘UN’’ or ‘‘NA’’ from sources of heat; 87– Stow “separated from” Class 1 as appropriate, be marked on the outside of a non-bulk packaging, but a minimum size for the identification number mark- ing is not currently specified. In this NPRM, PHMSA proposes to add specific size requirements for the identification number (‘‘UN’’ or ‘‘NA’’) marking. As proposed, the identification number must be marked on non-bulk packaging in characters at least 12mm (0.47 inches) high. However, packages having a maximum capacity of 30 liters (7.92 gallons) or 30 kg (66 pounds) or less must be marked with characters at least 6mm (0.2 inches) high. Packages having a maximum capacity of five liters (1.32 gallons) or 5kg (11 pounds) or less 36 Spray November 2012


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