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DOT Proposes Update to Rules for ID Numbers on Cargo Tanks Carrying Fuels

Posted on 11/21/2016 by Roger Marks

In today’s Federal Register, the US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed a rule to update the hazardous materials marking requirements for cargo tanks that carry petroleum-based fuels. The proposal is a direct response to the Protecting our Infrastructure of Pipelines and Enhancing Safety Act, or PIPES Act, signed into law in June 2016.

Among other things (see below), the PIPES Act requires PHMSA to collect public comments regarding petitions for rulemaking from the Commercial Vehicle Safety Alliance (CVSA) and the American Trucking Association (ATA), received in November 2015. These petitions request that DOT reconsider some of the specifics about marking ID numbers on cargo tanks.

What’s In This Proposed Hazmat Rule?

PCargo tank carrying fuelHMSA’s proposed rulemaking centers around a change made to the hazardous materials requirements in 2013 for compartmented cargo tanks and tank cars in rulemaking HM-219.  

The US DOT’s Hazardous Materials Regulations (HMR), found in 49 CFR Parts 171–180, et al., require that cargo tanks carrying petroleum-based fuels and fuel products (or other hazardous materials) be marked with UN identification numbers. These UN ID numbers provide emergency responders with critical information about the product when they respond to an emergency incident. These ID numbers can be marked on the hazard placard, on an orange panel, or on a white square-on-point configuration.

When shipping fuel, this information is crucial because some fuels may require different fire suppression measures or pose unique risks. Without an ID number, an emergency responder may not fully know the hazards he or she is dealing with in the field. For example, to put out a fire involving fuel with high ethanol content, firefighters need alcohol-resistant foam as opposed to regular extinguisher foam.

Marking UN ID Numbers on Compartmented Cargo Tanks


Compartmented cargo tanks can carry multiple types of fuel at once in separate compartments. So, are shippers required to mark the cargo tank with an ID number for every type of fuel on board?

Before the HM-219 rulemaking in 2013, 49 CFR 172.336(c) provided a list of exceptions to the requirement for marking all UN ID numbers on cargo tanks. HM-219 replaced the list of exceptions with a table. The new table, the Commercial Vehicle Safety Alliance (CVSA) says, creates confusion and lack of uniformity for shippers, enforcement personnel, and first responders. CVSA also argues that the updated Part 172.336 is inconsistent with the pre-HM-219 regulations.

For compartmented cargo tanks carrying different types of fuel, DOT does not require marking the ID number for every type of fuel being transported, provided that the ID number for the distillate fuel with the lowest flash point is marked. In addition, if the vehicle also contains a fuel blend with more than 10 percent ethanol, that ID number (3475 or 1987) must be marked as well. See 49 CFR 172.336(c).

What Is the PIPES Act?

Today’s rulemaking was proposed in response to the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016, signed into law by President Barack Obama on June 22, 2016.

The PIPES Act requires PHMSA to:

1.       Establish minimum safety standards for underground natural gas storage facilities,
2.       Update the minimum safety standards for some natural gas pipeline facilities, and
3.       Address ID number markings on cargo tanks.

What Happens Next for Fuel Shippers?

In its request for comments, PHMSA prompts interested parties to consider a number of questions, listed in the proposed rulemaking here. Once they’ve received and considered comments, PHMSA will decide whether or not to update the rules for marking ID numbers on compartmented cargo tanks carrying petroleum-based fuels and fuel products.  

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Tags: 49CFR, DOT, hazmat shipping, new rules, PHMSA

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