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23
23
2
Annual Report on
U.S. Department
of Transportation
Research and
Hazardous Materials
Special Programs
Administration
Transportation
Calendar Year 1987
515
515
LAMMABLE
ANNUAL REPORT
ON
HAZARDOUS MATERIALS TRANSPORTATION
HAZARDOUS MATERIALS TRANSPORTATION ACT
(TITLE 1, PUBLIC LAW 93-633)
CALENDAR YEAR 1987
TABLE OF CONTENTS
Page
Overview
(i)
Safety Performance Data
1
Special Emphasis Initiatives
12
Regulatory Program
16
Inspection and Enforcement
21
International Activities
29
Training and Information Dissemination
37
Technology Research
40
Appendix A - U.S. Coast Guard Activities
Appendix B - Rulemaking Publications Issued During 1987
Appendix C - Penalty Actions Taken During 1987
Appendix D - Exemptions or Special Permits
Granted in 1987
Appendix E - Memorandum of Understanding
between DOT/FEMA
OVERVIEW
Legislative Mandate
This report is required under Section 109 (e) of the Hazardous Materials
Transportation Act (HMTA), 49 U.S.C. Appendix § 1808. It describes the
Department's ongoing programs and policies for promoting hazardous materials
transportation safety, contains safety statistics and enforcement data, and
lists the regulations, as well as exemptions to the regulations, issued
during the reporting year.
While the HMTA provides the primary legislative authority for the
Department's hazardous materials programs, a number of other related statutes
also guide the program. Among these are the Dangerous Cargo Act of 1940,
Sections 601. (c) and 902(h) (1) of the Federal Aviation Act of 1958, the Tank
Vessel Act of 1936, the Ports and Tanker Safety Act of 1978, the Federal
Railroad Safety Act of 1970, Section 311 of the Federal Water Pollution
Control Act Amendments of 1972, and the Resource Conservation and Recovery
Act of 1976. These statutes are, for the most part, mode specific and the
Department's modal administrations- States Coast Guard (USCG), Federal
Aviation Administration (FAA), Federal Highway Administration (FHWA), and
Federal Railroad Administration (FRA) retain jurisdictional responsibility
for enforcement actions relating to transportation by water, air, highway,
and rail, respectively.
The HMTA empowers the Secretary of Transportation to issue and enforce
regulations deemed necessary to ensure the safe domestic and international
movement of hazardous materials. This authority has been delegated to the
Administrator, Research and Special Programs Administration (RSPA), who is
responsible for departmental coordinated action to promote hazardous
materials transportation safety.
RSPA develops and issues regulations of single and multimodal
applicability governing hazardous materials definition and classification,
shipper and carrier operations, and packaging and container specifications.
This is accomplished in coordination with the modal administrations. RSPA's
regulatory responsibilities also extend to enforcement of those regulations
governing the manufacture, reconditioning, and retesting of DOT specification
containers, and the multimodal shipment of hazardous materials.
The United States Coast Guard issues and enforces regulations applicable
to the transportation of bulk hazardous materials by vessel as required by
46 CFR, subchapters D (Tank Vessels), I (Cargoes and Miscellaneous Vessels),
N (Dangerous Cargoes), and 0 (Certain Bulk Dangerous Cargoes). In keeping
with the requirement in the HMTA for a " comprehensive report on the
transportation of hazardous materials " data presented in this report
pertains to the transportation by vessel of both bulk and break-bulk
(packaged) hazardous materials. A description of the Coast Guard's bulk
hazardous materials program appears as Appendix A.
(i)
Program Highlights
Responsibility for issuing and enforcing regulations deemed necessary
for the safe domestic and international movement of hazardous materials and
for a coordinated departmental approach to promoting hazardous materials
transportation safety rests with RSPA. This responsibility is met with the
full coordination and cooperation of the modal administrations.
Highlights of important initiatives and accomplishments are summarized
below:
- On July 30, 1987, the Department transmitted to Congress a major
legislative proposal which would represent the first substantive
amendment of the HMTA since its passage in 1974. The key issues of
this proposal include permitting, uniformity, and routing.
- Several rulemaking actions were taken in 1987 including proposals
designed to:
Replace specification packaging requirements for non-bulk
packagings with performance-oriented packaging standards.
Extend the application of the Hazardous Materials Regulations to
all intrastate transportation of hazardous materials.
Improve the packaging requirements for uranium hexafluoride.
Improve emergency response communication by requiring the placement
of emergency response information on shipping papers and response
action information in all places including vehicles.
Require states to give written notice to RSPA of designated
alternative routes for highway route-controlled quantity of
radioactive materials and require carriers rather than shippers to
file route plans on similar shipments to RSPA.
Improve the incident data collection system by revising the
reporting form to provide more meaningful information.
- RSPA issued five inconsistency rulings and three decisions on appeal
under Section 112 "Relationship to Other Laws" of the HMTA.
Significant decisions included:
The IR-17 appeal, which affirmed the decision that a State law
imposing a fee of $1,000 per cask of spent nuclear fuel transported
through the State, which is used to fund consistent inspection and
emergency response programs, was consistent,
IR-19, in which it was determined that State Regulations containing
burdensome and discretionary permitting system for railroad-related
loading, unloading, transfer, and storage of hazardous materials
were inconsistent, and; 1
(ii)
O IR-22, in which it was determined that City regulations on cargo
containment systems, equipment, and related areas were inconsistent
because they involved exclusively Federal areas and caused delays.
- RSPA undertook or continued work on the following projects in support
of its continuing focus on interaction with other Federal and state
agencies and constituency groups concerned with hazardous materials
transportation safety:
o Implemented recommendations that evolved from the Cooperative
Hazardous Materials Enforcement Development (COHMED) workshops
conducted during the year including the development of a menu-
driven program to enable States to tap into the Department's
exemptions and interpretations data bases; development of a
Hazardous Materials Modular Inspection/Enforcement Training
Package; and expanding the scope of COHMED activities to include
emergency response planning and training.
o In cooperation with the Department of Energy, the Nuclear
Regulatory Commission, and the Federal Emergency Management Agency,
conducted a series of regional workshops focusing on radioactive
materials transportation issues.
Completed a Memorandum of Understanding with FEMA that delineated
areas of responsibility for emergency response planning and
training and identified areas of cooperation in developing
emergency management programs and emergency response initiatives.
o Instituted, jointly with FEMA, an electronic Hazardous Materials
Information Exchange (HMIX) that provides state and local emergency
response officials with timely information on hazardous materials
emergency management. By year's end the system was expanded to
include information on most facets of hazardous materials
transportation.
- FRA and RSPA continued to monitor spent nuclear fuel shipments from
point of origin to final destination.
- Under the aegis of the Motor Carrier Safety Assistance Program (MCSAP)
participating states inspected 96,730 hazardous materials - carrying
vehicles.
- The Emergency Response Guidebook was completely revised in 1987 and a
total of approximately one million copies printed and distributed.
- RSPA has begun a comprehensive review and assessment of our data
collection program which will be completed in 1988. The review and
assessment, performed by the Transportation Systems Center (TSC), is
evaluating the current use of the data, reviewing our current program,
and contacting a variety of our constituents such as states. TSC will
be making recommendations as to further information we should be
collecting and how we can make better use of existing data.
(iii)
- RSPA increased its inspection staff to 10, an addition of 3 over the
previous year. This action resulted in increases over 1986 of 8
percent in inspections conducted, over 100 percent in penalty actions
initiated and 33 percent each in warning letters issued and penalties
collected.
Note: This Report covers Calendar Year 1987. Studies scheduled to be
conducted in 1988 will be reported on in the Calendar Year 1988 Report.
(iv)
SAFETY PERFORMANCE DATA
A truly effective hazardous materials transportation management program
depends on its information base. Priorities for safety regulation
development, enforcement, research and training are set in part by
information on the safety performance of the hazardous materials
transportation industry.
The Department's principal instrument for compiling, analyzing and
disseminating hazardous materials transportation safety data is the Hazardous
Materials Information System (HMIS) which contains comprehensive system
performance data in incidents, enforcement actions, exemptions and approvals
and other elements of the regulatory program. In combination with other
factors, data from the HMIS are used to identify emerging safety problems,
justify proposed regulatory solutions, monitor compliance efforts, and
support and illustrate training programs. The HMIS is used extensively
within the Department and other Federal agencies, and by State and local
governments, the press and public. In 1987, RSPA responded to 285 data
requests.
The HMIS is an evolving system. Recently, additional emphasis has been
placed by the Department in enhancing the system to encompass additional
functions and to support new users. In response to recommendations by the
Secretary's Safety Review Task Force and from the Office of Technology
Assessment, emphasis has been placed on upgrading system equipment and
software. RSPA also undertook a number of significant actions to increase
the utilization of the HMIS. New computer hardware for the exclusive support
of the HMIS was placed into service in FY 87. In addition to enhancing
system reliability and capability, it is expected to pay for itself with two
years based on previous years operating costs.
In cooperation with the Environmental Protection Agency, the United
States Coast Guard and others, RSPA designed and tested a unified data system
for telephonic reports of spills. Maintained as part of the HMIS, the system
records spills required to be reported under RSPA, USCG and EPA regulations.
The system went operational on January 1, 1987, and has been expanded to
include EPA and USCG regional data.
With the continued expansion of the HMIS user community to include
infrequent users, efforts have been accelerated to simplify and enhance user
accessibility. User-friendly, menu-driven software was developed to access
the Exemption subsystem of the HMIS, with testing and deployment completed in
FY 87. Using only a series of simple multiple choice type questions, the
user is able to quickly obtain comprehensive data base information.
Finally, a major independent review of the HMIS was begun by the RSPA's
Transportation Systems Center, encompassing both the hazardous materials and
pipeline subsystems. This multiyear review will evaluate the feasibility,
benefits, costs and priority of suggested system improvements and is
scheduled to be completed in FY 88.
1
Safety Statistics
Exhibit 1 and the companion Figures I - VI summarize system performance
over the past eight years. The data reveal that the general decline in the
number of reported incidents involving hazardous materials, begun in 1979,
continued into 1987. Highway incidents account for approximately 76 percent
of the incidents resulting in injuries and for all of the fatalities. These
injuries and fatalities were attributable to 153 incidents.
Exhibit 2 shows the state-by-state breakdown of hazardous materials
incidents for 1987, including deaths, injuries and property damage. As
expected, in general, larger and more industrialized states have a greater
incidence of hazardous materials spills, injuries and damages. A similar
pattern is not expected or observed for deaths due to the small number of
occurrences.
Exhibit 3 displays by hazard class the total number of incidents and the
amount of associated damages reported in 1987. The left side of the table
presents in rank order incidents by hazard class. The top portion of the
table consists of the top four hazard classes that accounted for almost 87
percent of the reported incidents in 1987, while the number of incidents
occurring in the other hazard classes appears directly below. The right side
of the table lists, by hazard class, the amount of damages; the rank of
damages; the percentage of total damages; and the number of incidents
involving damages.
Exhibit 4 displays the injuries which occurred in 1987 by hazard class
in actual numbers and percentages. Also shown is the breakdown of major and
minor injuries, along with the number of incidents involving injuries in each
hazard class.
Exhibit 5 lists the commodities and corresponding hazard class involved
in fatalities during 1987. Gasoline, with its large and daily volume of
transport throughout the U.S., accounted for the greatest number of
fatalities (6) during the past year.
Exhibit 6 shows the general cause of incidents involving hazardous
materials transportation grouped into four categories, by mode, that occurred
in 1987. The actual number of incidents in each mode by attributable cause
is shown, along with corresponding percentages.
Exhibit 7 displays the release cause of hazardous materials among the
modes, broken down by bulk/nonbulk shipments. The percentage of total
failures attributable to each release cause is shown under a modal and bulk
and nonbulk grouping. The causes listed are those contained in the HMIS, and
the number of total releases include both the primary and secondary failure
causes of containers. [Exhibits 1 - 7 follow]
2
Exhibit 1
Incident Statistics by Mode and Reporting Year
Mode
1980
1981°
1982
1983
1984
1985
1986
1987
Total
Air
226
160
96
67
107
114
122
177
1063
Highway
14,181
8,669
5,671
4,879
4,509
4,749
4,612
4984
52,252
Railway
1,272
1,145
838
868
996
842
855
919
7,735
Water
34
8
9
12
9
7
7
12
98
Freight Forwarder
2
3
6
1
145
298
150
120
725
Other
29
63
1
1
6
6
12
3
121
TOTALS
15,744
10,048
6,621
5,828
5,772
6,016
5,758
6,215
61,994
Deaths by Mode and Incident Year
Air
0
0
0
0
0
0
0
0
0
Highway
17
25
13
8
6
8
16
11
104
Railway
2
0
0
0
0
0
0
0
'2
Water
0
0
0
0
1
0
0
0
1
Freight Forwarder
0
0
0
0
0
0
0
0
0
Other
0
0
0
0
0
0
0
0
0
TOTALS
19
25
13
8
7
8
16
11
107
Injuries by Mode and Incident Year
Air
8
7
0
3
15
4
12
29
78
Highway
494
394
88
118
145
195
229
250
1,913
Railway
121
222
36
68
76
53
59
23
658
Water
1
1
1
0
18
0
2
8
31
Freight Forwarder
1
0
0
0
3
1
12
28
45
Other
2
18
0
0
0
0
2
0
22
TOTALS
627
642
125
189
257
253
315
338
2,747
Damages by Mode and Incident Year
Air
12,286
6,860
26,851
52,575
771,226
12,524
57,017
14,983
954,122
Highway
7,367,972
14,200,784
11,382,169
9,254,885
11,120,358
12,619,212
13,103,623
15,749,873
94,795,876
Rallway
2,952,508
3,652,682
4,138,265
2,559,130
3,353,339
10,273,671
3,077,925
7,439,468
37,448,988
Water
505,408
53,045
30,000
76,088
509,849
6,484
53,500
85,230
1,319,604
Freight Forwarder
100
8,500
35
300
14,011
13,918
102,117
51,126
188,107
Other
34,560
70,010
200
16,500
975
515
3,385
200
126,345
TOTALS
10,872,834
17,989,581
15,577,520
11,959,478
15,769,758
22,926,324
16,397,567
23,340,880
134,831,042
. Effective January 1, 1961, the reporting requirements were changed to exclude Incidents Involving consumer commodities, wet electric
storage batteries, or paint, enamel, lacquer, stain, shellac, etc., In packaging of 5 gallons or smaller unless the Incident results In death,
Injury or property damage over $50,000; the material is being transported by air, or the material is classified as a hazardous waste.
Preliminary data as of April 27, 1988
3
Figure I
Hazardous Materials Incidents, 1980-1987
16000
15744
14000
12000
10048
10000
8000
6621
6215
6016
6000
5828
5772
5758
4000
2000
0
80
81
82
83
84
85
86
87
Preliminary data as of April 27, 1988
Figure II
Hazardous Materials Fatalities, 1980-1987
25
25
20
19
16
15
13
11
10
8
8
7
5
0
8
La
82
83
84
85
86
87
Preliminary data as of April 27, 1988
4
Figure III
Reported Incidents by Rail
1300
1,272
1250
1200
1150
1,145
996
950
919
900
850
855
868
838
842
800
80
81
82
83
84
85
86
87
Preliminary data as of April 27, 1988
Figure IV
Reported Incidents by Water
50
45
40
35
34
30
25
20
15
12
12
10
8
9
9
7
7
80
81
82
83
84
85
86
87
Preliminary data as of April 27, 1988
5
Figure V
Reported Incidents by Air
300
250
226
200
177
160
150
122
100
96
114
107
50
67
80
81
82
83
84
85
86
87
Preliminary data as of April 27, 1988
Figure VI
Reported Incidents by Highway
14181
14000
12000
10000
8669
8000
6000
5671
4984
4076
4749
4612
4509
4000
2000
80
81
a
83
84
85
86
87
Preliminary data as of April 27, 1988
6.
Exhibit 2
Hazardous Materials Incidents by State-1987
All Modes
State
Incidents
Dead
Injuries
Damages
State
Incidents
Dead
Injuries
Damages
Alabama
103
0
4
566,799
Montana
15
0
0
155,487
Alaska
9
0
0
27,577
Nebraska
31
0
0
19,005
Arizona
53
0
5
78,451
Nevada
29
0
0
57,440
Arkansas
96
1
2
555,101
New Hampshire
8
0
1
93,220
California
372
2
52
1,712,616
New Jersey
173
0
16
311,794
Colorado
80
0
1
159,220
New Mexico
59
1
4
89,801
Connecticut
44
0
3
99,539
New York
240
0
11
689,612
Delaware
16
0
1
50,320
North Carolina
191
2
8
4,104,435
Dist. of Col.
7
0
0
3,500
North Dakota
7
0
0
7,785
Florida
155
1
3
529,479
Ohio
441
0
11
770,122
Georgia
203
0
3
348,668
Oklahoma
46
0
1
47,779
Hawaii
5
0
1
49,320
Oregon
70
0
0
60,443
Idaho
22
0
0
Pennsylvania
540
0
117,829
13
512,476
Illinois
Rhode Island
8
461
0
0
38
0
879,365
2,905
Indiana
South Carolina
65
0
0
201
0
14
244,965
298,534
South Dakota
5
lowa
0
0
179
131
0
4
82,935
Tennessee
229
0
7
Kansas
131
3
1
222,786
102,951
Texas
423
1
30
Kentucky
6,981,628
97
0
0
41,364
Utah
64
0
0
Louisiana
66,822
140
0
54
1,004,455
Vermont
7
0
0
49,798
Maine
16
0
0
177,886
Virginia
99
0
6
253,540
Maryland
141
0
1
249,349
Washington
106
0
8
66,419
Massachusetts
87
0
2
289,972
West Virginia
39
0
0
210,049
Michigan
192
0
5
287,694
Wisconsin
135
0
12
30,032
Minnesota
82
0
0
122,864
Wyoming
25
0
0
91,418
Mississippi
67
0
9
116,084
Puerto Rico
9
0
5
13,885
Missouri
184
0
2
194,774
. Other
8
0
0
40,457
. Shipments originating In the U.S. but Incident occurring elsewhere.
Preliminary data as of April 27, 1988
7
EXHIBIT 3
INCIDENTS AND DAMAGES BY HAZARD CLASS-1987
TOP FOUR
TOP FOUR
PERCENT OF
PERCENT
NO.OF
REPORTED
REPORTED
AMOUNT OF
RANK BY
OF TOTAL
INCIDENTS
HAZARD CLASS
INCIDENTS
RANK
INCIDENTS
DAMAGES
DAMAGES
DAMAGES
INVOLVING
DAMAGES
Corrosive Material
2,469
1
39.7
$ 2,114,398
3
9.1
1,766
Flammable Liquid
2,358
2
37.9
12,156,535
1
52.1
1,770
Combustible Liquid
356
3
5.7
3,831,380
2
16.4
269
Poison Liquid or Solid C1 B
225
4
3.6
1,662,068
4
7.1
173
TOTAL
5,408
86.9
$19,764,381
84.7
3,978
OTHER
OTHER
8
Oxidizer
214
5
3.4
$
919,689
6
3.9
164
Non Flammable Compressed Gas
163
6
2.6
126,547
10
.5
49
Other Regulated Material C1 A
114
7
1.8
1,512.940
5
6.5
74
Flammable Compressed Gas
101
8
1.6
196,231
8
.8
42
Other Regulated Material C1 E
86
9
1.4
422,506
7
1.8
54
Flammable Solid
46
10
.7
10,449
15
.1
31
Organic Peroxide
39
11
.6
119,820
9
.5
35
Radioactive Material
15
12
.2
790
17
.1
5
Other Regulated Material C1 B
14
13
.2
83,162
11
.4
10
Other Regulated Material C1 D
4
14
.1
0
20
0
0
Irritating Material
3
15
.1
15
19
.1
2
Poison Gas or Liquid C1 A
2
16
.1
54,500
14
.2
2
Explosives C1 A
2
16
.1
60,050
13
.3
2
Other Regulated Material C1 C
2
16
.1
67,250
12
.3
1
Explosives C1 B
1
17
.1
2,500
16
.1
1
Explosives C1 C
1
17
.1
50
18
.1
1
TOTAL
807
13.2
$ 3,576,499
15.7
473
GRAND TOTAL
6,215
$23,340,880
4,451
Legend: A11 % figures tounded to nearest .1%
Preliminary data as of April 27, 1988
Exhibit 4
Injuries by Hazard Class*-1987
Total Number
Percent of
Number of
Number of
Number of
Hazard Class
of Injuries
Total Injuries
Major Injuries
Minor Injuries
Incidents with
Injuries
Corrosive Material
110
32.5
14
96
80
Flammable Liquid
78
23.1
8
70
36
Other Regulated Material,
Class A
18
5.3
0
18
6
Combustible Liquid
34
10.1
0
34
5
Flammable Compressed
Gas
13
3.8
1
12
4
Poison Liquid or Solid,
Class B
8
2.4
0
8
4
Oxidizer
5
1.5
0
5
4
Non Flammable
Compressed Gas
66
19.5
0
66
3
Other Regulated Material,
Class E
6
1.8
6
0
1
TOTAL
338
100%
29
309
143
Legend: All % figures rounded to nearest .1%.
. No reports received for other hazard classes
:. Major Injuries are those requiring hospitalization, or Involving 2nd or 3rd degree burns, or resulting in Injury-related loss of
time minor. at work of one or more days, such as would be caused by inhalation of strong irritating vapors. All other Injuries are considered
Preliminary data as of April 27, 1988
Local
9
EXHIBIT 5
FATALITIES BY COMMODITY - 1987
COMMODITY
HAZARD CLASS
FATALITIES
Gasoline
Flammable Liquid
6
Ammonia, Anhydrous
Nonflammable/Compressed Gas 1
Hydrochloric Acid
Corrosive Material
1
Petroleum Naphtha
Flammable Liquid
1
Propellant Explosive
Explosive, Class B
1
Sulphuric Acid
Corrosive Material
1
TOTAL
11
Preliminary data as of April 27, 1988
Exhibit 6
Incident Cause by Mode-1987
Air
Highway
Rail
Other
Total
Percent of
Including Water
all Incidents
Human Error
120
3,416
335
95
3,966
63.8
Package Failure
56
1,300
511
40
1907
30.7
Vehicle Accident/
Derailment
0
247
65
e
212
5.0
Other
1
21
8
0
30
.5
TOTAL
177
4,984
919
135
6,215
Percent of Incidents
By Mode
2.8
80.2
14.8
2.2
Preliminary data as of April 27, 1988
10
Exhibit 7
Percentage of Incidents by Release Cause by Mode-1987
AIR
HIGHWAY
RAIL
OTHER
TOTAL
Release Cause
Non
Non
Non
Non
Non
Bulk
Bulk
Bulk
Bulk
Bulk
Bulk
Bulk
Bulk
Bulk
Bulk
Dropped
-
19.6
2.0
11.0
.6
2.3
-
5.8
1.3
10.9
External Puncture
-
13.0
6.4
25.7
2.2
33.6
12.5
26.5
4.4
25.4
Damage by Other Freight
-
8.8
.2
12.5
-
8.6
-
12.9
.1
12.3
Water Damage
-
-
-
.1
-
-
-
-
-
.1
Damage From Other Liquid
-
-
-
.1
.1
-
-
-
.1
.1
Freezing
-
-
.1
.1
-
-
-
-
.1
.1
External Heat
-
-
.2
.2
2.2
.8
-
.6
1.2
.2
Internal Pressure
-
5.1
1.8
1.1
6.4
-
-
.6
4.0
1.2
Corrosion On Rust
-
.5
1.0
.7
1.0
-
12.5
3.9
1.0
.7
Defective Fittings
-
7.9
8.8
4.7
27.0
2.3
25.0
4.5
17.7
4.7
Loose Fittings
-
26.5
13.1
16.0
36.0
7.0
12.5
14.2
24.2
16.2
Failure of Inner Receptacles
-
.5
.2
.2
.2
-
-
-
.2
.2
Bottom Failure
-
1.4
.7
4.2
.9
4.7
25.0
6.5
.9
4.2
Bodyside Failure
-
1.9
2.0
3.8
2.2
2.3
-
6.5
2.1
3.8
Weld Failure
-
.9
2.2
.8
.8
.8
-
.6
1.5
.8
Chime Failure
-
.9
-
.7
-
3.1
-
1.3
-
.8
Other Condition
-
4.2
4.8
1.3
2.3
3.9
-
1.3
3.6
1.5
Hose Burst
-
-
4.0
-
.2
-
-
-
2.1
-
Loading/Unloading Spill
-
-
4.9
.1
.3
-
12.5
1.3
2.8
.1
Improper Blocking/Bracing
-
2.8
.2
4.2
-
18.0
-
7.1
.1
4.5
Improper Loading
-
3.3
.7
9.8
.5
8.6
-
5.2
.6
9.4
Vehicular Accident/Derallment
-
-
18.8
1.0
7.3
1.6
-
-
13.2
1.0
Venting
-
-
.6
.1
2.1
-
-
-
1.3
.1
Release of Fumes
-
2.8
.5
.4
6.5
.8
-
.6
3.4
.5
Friction Between Containers
-
-
.1
.4
-
1.6
-
-
.1
.4
Static Electricity
-
-
.1
-
-
-
-
-
.1
-
Metal Fatigue
-
-
-
.8
-
-
-
.6
-
.8
Spill Human Error
-
-
21.0
.1
1.1
-
-
-
11.3
.1
Storage Tank Failure
-
-
5.5
-
-
-
-
-
2.8
-
Total Releases
0
215
1,233
5,203
1,158
128
8
155
2,399
5,701
Legend: All figures rounded to nearest 1%
- denotes no reports received
. Includes water.
: Total Releases include both primary and secondary releases
Preliminary data as of April 27, 1988
11
SPECIAL EMPHASIS INITIATIVES
Reauthorization of the Hazardous Materials Transportation Act
On July 30, 1987, the Department transmitted to Congress a major
legislative proposal which would represent the first substantive amendment of
the HMTA since its passage in 1974. The proposal would:
- eliminate confusion by clearly delineating Federal, state and local
roles;
- recognize concurrent jurisdiction in state and political subdivisions
to do highway routing;
- establish a limited safety permitting program for motor carriers of
hazardous materials toxic by inhalation, class A and B explosives, and
highway route controlled quantities of radioactive materials (e.g.
spent nuclear fuel)
- establish a dispute resolution mechanism to resolve conflicts between
and among States arising from highway routing decisions;
- provide a statutory basis for the Department to determine the validity
of State or political subdivision requirements which may conflict with
the Act or the Hazardous Materials Regulations (HMR), to replace the
current advisory process provided by regulation.
- clearly extend the Act and the HMR to intrastate operations.
Cooperative Hazardous Materials Enforcement Development
The Cooperative Hazardous Materials Enforcement Development (COHMED)
Program, in existence since 1985, underwent an extensive restructuring in
1987. This cooperative program which focuses exclusively on hazardous
materials transportation was developed to enhance and complement the
hazardous materials initiatives of the Motor Carrier Safety Assistance
Program (MCSAP), a grant-in-aid program for motor carrier assistance. COHMED
does not fund states directly (MCSAP does). It provides technical
assistance, training, and information to states for development of their
enforcement programs, fosters state adoption and enforcement of the Federal
Hazardous Materials Regulations and thus promotes uniformity and consistency
in regulation and enforcement.
The Department's hazardous material transportation enforcement program
was enhanced by a steadily improving coordination and involvement with the
MCSAP program for state highway enforcement of the motor carrier and
hazardous materials transportation regulations. RSPA actively participated
in MCSAP Tri-Regional meetings in three locations in 1987. These meetings
provided an opportunity for closer cooperation and improved understanding of
common goals among RSPA, FHWA's Office of Motor Carriers (OMC) and the
12
states. Such meetings have proved invaluable for effectively allocating
staff and funding resources to enhance state enforcement of the hazardous
materials regulations.
RSPA also participated in the Office of Motor Carriers' technical review
of State Enforcement Plans (SEP's) for FY 88 to ensure that states maintained
adequate emphasis on hazardous materials transportation in their enforcement
planning. States requesting funds under MCSAP are required to submit an
annual State Enforcement Plan to the Office of Motor Carriers describing
their proposed use of any funds allocated under the program. OMC and RSPA
review these plans at the developmental and final stages for conformity with
the criteria set forth for qualification for a grant. From the involvement
of RSPA in the SEP process at both stages, it has become evident that review
and coordination at the planning stage is the most effective way of assuring
effective hazardous materials enforcement under MCSAP.
During FY 87, RSPA provided a forum for states to meet and discuss
common interests concerning hazardous materials transportation safety through
a national COHMED workshop in San Diego, California. In response to state
concerns expressed in this workshop, RSPA intensively reorganized the COHMED
program and placed a greater emphasis on state agency direction toward common
solutions to variances in state enforcement authorities and practices. RSPA
also plans to sponsor a series of Federal/state regional workshops to be held
in 1988 in Florida, Arizona, Massachusetts and Missouri. Strong attendance
from surrounding states is anticipated.
Transportation of Radioactive Materials
The radioactive materials transportation safety record has been
excellent. In over four decades of transporting radioactive materials in the
United States, there has never been a death or serious injury due to a
release of radioactive materials.
RSPA engaged in several rulemaking projects in 1987 which were directly
related to the transportation of radioactive materials. The Hazardous
Materials Regulations were amended to reference the American National
Standards Institute (ANSI) standard addressing the construction, cleaning,
repair, periodic inspection and testing of packagings used for transporting
Uranium hexafluoride. Additional rulemaking was initiated proposing that:
(1) states which designate alternative routes for highway route-controlled
quantities of radioactive materials give written notice of such designations
to RSPA, and (2) carriers, rather than shippers, file route plans and other
information on highway route-controlled shipments of radioactive materials.
RSPA conducts surveillance inspections at radioactive materials shipper
facilities and carrier terminals, including those carriers transporting large
amounts of radioactive materials under DOT exemptions; monitors radioactive
materials moving through ports and air freight terminals; assists the modal
administrations in conducting pre- and post-trip inspections of certain spent
nuclear fuel shipments, as well as in other areas of radioactive materials
transportation where assistance is requested; and monitors the route plans
for highway route-controlled quantities of radioactive materials required by
13
regulation to be filed with RSPA. Sixteen percent of all RSPA inspections
carried out in 1987 were of radioactive materials shippers and shipments.
Five regional TRANSRAM workshops focusing on states' problems and
concerns regarding radioactive materials transportation were held during the
year. The meetings were sponsored by RSPA with the participation of DOE,
NRC, and FEMA and were intended to promote coordination and cooperation among
states, Indian Nations, and Federal agencies having regulatory and
enforcement responsibilities for the transportation of radioactive materials.
These workshops will be continued on a regional basis through 1988.
Emergency Response
Recent legislative initiatives at all levels of government have
emphasized the need for emergency planning and preparedness for response to
hazardous materials transportation accidents. The three principal Federal
agencies involved in hazardous materials emergency response activities are
FEMA, EPA and DOT. RSPA has endeavored to increase coordination and
communication among these agencies toward achieving a uniform, consistent
policy for hazardous materials emergency management.
In recognition of a need for clarification of overlapping
responsibilities for emergency response, the Department completed a
Memorandum of Understanding with FEMA to more clearly define our respective
roles and identify areas of possible collaboration in developing strong
emergency management and training programs. (A copy of the MOU is attached
as Appendix E)
RSPA's commitment to increasing coordination and communication among
agencies with emergency management planning responsibilities extends to its
membership on the National Response Team (NRT). The NRT is primarily a
planning, policy and coordinating body chaired by the EPA, co-chaired by the
Coast Guard and composed of 14 Federal Agencies with interests and expertise
in various aspects of emergency response to pollution incidents. The NRT
develops and executes the National Contingency Plan for emergency response to
discharges of oil into the navigable waters of the United States and releases
of chemicals into the environment. RSPA's participation on the NRT ensures
that the unique issues concerning emergencies involving hazardous materials
in transport are adequately addressed.
In 1988, RSPA plans a DOT/FEMA sponsored workshop on emergency response
for senior policy makers of Federal agencies, state and local governments,
and the private sector. The purpose of the workshop is to gain assistance
from the participants in formulating policy recommendations and determining
new program initiatives.
RSPA has provided substantial assistance to state and local governments'
hazardous materials emergency response efforts through a variety of
conferences, workshops, publications and training materials. One of RSPA's
most significant contributions in this regard has been the development of the
Emergency Response Guidebook which is a guide to first responders' actions at
14
the scene of a hazardous material incident. A second contribution is the
RSPA/FEMA implementation of an electronic hazardous materials information
exchange that offers users (states, individuals, industry) ready access by
computer or toll free telephone to current hazardous materials transportation
and emergency response planning and training information. A more detailed
description of the system is contained in the section on training which
follows.
15
REGULATORY PROGRAM
The Research and Special Programs Administration is the primary element
within the Department of Transportation responsible for developing a national
regulatory program to protect against the risks to life and property inherent
in the transportation of hazardous materials. Embodied in this regulatory
program is the responsibility for the promulgation of regulations governing
the transportation of such materials and the issuance of amendments and
exemptions thereto. Because of the multi-modal nature of hazardous materials
transportation, RSPA relies extensively on the participation of the four
modal administrations in the promulgation of regulations. Participation in
international standards-setting organizations to ensure that the U.S.
hazardous materials industry is not confronted with a multitude of
conflicting or inconsistent requirements for shipping and handling hazardous
materials, is also a key element in the regulatory program.
The Hazardous Materials Regulations cover classification, packaging,
handling, incident reporting, and hazard communication requirements
applicable to the transportation of hazardous materials. They are
continually reviewed and amended to eliminate obsolete or unnecessary
requirements, address safety concerns, or convert the provisions of
exemptions into regulations of general applicability.
The rulemaking process evolves from one or more of four sources:
petitions for rulemaking received from the general public or other government
agencies; rulemaking proposals from the four modal administrations; RSPA
initiatives to improve existing regulations, convert exemptions into
regulations of general applicability, or address unusual situations not
presently covered by the rules; or the need to change existing regulations as
a result of RSPA's enforcement experiences. Whatever the impetus that drives
the need for rulemaking, the process encourages the direct involvement of the
public in formulating the regulation through the solicitation of comments at
the time of issuance of Advance Notices of Proposed Rulemaking (ANPRM) and
Notices of Proposed Rulemaking (NPRM). Publication of a final rule is the
culmination of the rulemaking process and occurs only after analysis of all
public comments, internal and external coordination, and examination of its
potential impacts.
During 1987, RSPA issued nine amendments to the regulations and
published 13 ANPRM's and NPRM's for comment. The amendments and proposed
changes to the regulations are listed in Appendix B. Ongoing regulatory
actions address a variety of issues including the following:
Performance-oriented Packaging Standards- In May and November of
1987, RSPA issued NPRMs proposing to replace specification packaging
requirements for non-bulk packagings with performance-oriented packaging
standards based on the United Nations Committee of Experts'
Recommendations on the Transport of Dangerous Goods (UN
Recommendations). Also proposed were the adoption of hazard
classification procedures and communication requirements generally
consistent with international regulations based on the UN
Recommendations and certain safety initiatives related to bulk
16
packagings, materials which are toxic by inhalation and other subjects.
The proposed changes are intended to simplify and reduce the volume of
regulations, facilitate international commerce, and promote safety
through improvements to packaging and hazard communication. A public
hearing was held in Washington, D.C., in November 1987. The comment
period will end in early 1988, at which time RSPA will begin a detailed
review and evaluation of public comments to the docket.
Emergency Response Communication- New standards for emergency
response communication were proposed in 1987. These included requiring
that emergency response information be included on shipping papers, and
also having this information available on transport vehicles and at
transportation facilities where hazardous materials are handled. The
proposal is intended to improve emergency response communications and
the availability of information for handling hazardous materials during
incidents. RSPA is currently evaluating comments.
Intrastate Transportation of Hazardous Materials- In June of 1987,
RSPA issued an ANPRM proposing to extend application of the hazardous
Materials Regulations to all intrastate transportation of hazardous
materials in commerce as a means of promoting national uniformity and
transportation safety. RSPA is currently evaluating comments.
Uranium Hexafluoride- In 1987, RSPA published a revision to a final
rule issued in 1986 concerning design criteria for certain types of
packages used for the transport of uranium hexafluoride. Also an NPRM
was published to address maintenance and continued user of older types
of uranium hexafluoride packaging. RSPA is currently evaluating
comments
Route Designation Communication- Two rulemaking actions were begun
in 1987 relating to the transportation of route controlled quantities of
radioactive materials. The first was a proposal to require that state
agencies designating alternative routes for the transportation of
radioactive materials give written notice of such designations to RSPA.
The second proposed that carriers, rather than shippers, be required to
give RSPA written notice of route plans.
Marine Portable Tanks- The Coast Guard began work on a rulemaking
which would discontinue the design specification in 46 CFR Part 64 for
marine portable tanks (MPTs) and authorize DOT Specification IM 101 and
IM 102 portable tanks to be loaded and discharged while on board
vessels. Design approval and inspection by the Coast Guard would be
replaced by third-party inspection and approval. A Notice of Proposed
Rulemaking is expected to be published in March 1988.
There were also a number of joint rulemaking actions underway in 1987.
Cargo Tank Requirements- FHWA and RSPA continued to evaluate the
comments received under Docket No. HM-183, 183-A pertaining to
requirements for cargo tanks. A series of working meetings were held in
Washington, D.C., in 1987 with certain trade associations to discuss
17
comments on the proposed revisions to requirements for cargo tanks. The
discussions addressed the manufacture, repair, requalification and
operation of DOT specification cargo tanks and enabled both FHWA and
RSPA to receive additional supportive information, and clarification on
data which had been submitted by commenters. A final rule should be
forthcoming towards the end of 1988.
Transport of Explosives by Vessels- The Coast Guard and RSPA moved
forward with the consolidation of the regulations on military explosives
contained in 46 CFR Part 146 with those in Title 49 applying to all
types of explosives. The rules governing the transport of explosives by
vessel would be extensively revised to align them with recently proposed
amendments to the International Maritime Dangerous Goods (IMDG) Code. A
Notice of Proposed Rulemaking is expected to be published in the summer
of 1988.
Portable Tanks for Combustible Liquids- The Coast Guard and RSPA
continued a joint project to establish regulations which would permit
the carriage by vessel of combustible liquids in portable tanks designed
in accordance with the requirements for DOT Specification 57 portable
tanks, but which have a greater capacity and would not be required to
pass a vibration test due to their large size. This type of portable
tank is currently being used in the offshore oil industry under a Coast
Guard approval program. This project is expected to result in a
substantial savings of time and money for both the regulated industry
and the Coast Guard. This action will be included with the proposed
miscellaneous amendments (HM-166W) to be published by RSPA in the spring
of 1988.
EXEMPTIONS
RSPA is authorized to grant exemptions to the Hazardous Materials
Regulations that permit practices and procedures not specifically authorized
in the regulations. Codified regulations are static in nature but hazardous
materials transportation exists in a changing environment. Literally
hundreds of new chemical mixtures or variations of existing mixtures are
introduced into commerce each year. New packaging techniques are
continuously under development, and there are a host of peculiar shipping
situations and needs for the one-time movement of materials that cannot
possibly be addressed by a single set of codified regulations. The exemption
program provides a mechanism whereby these new materials, packaging
innovations, and peculiar shipping situations may be evaluated and authorized
at an equivalent level of safety or at a level of safety consistent with the
public interest and the policy of the Hazardous Materials Transportation Act.
Many exemptions eventually result in new regulations thereby authorizing
these innovative practices to the entire population of hazardous materials
shippers, carriers, and container manufacturers.
Exemption applications consist of requests for new exemptions, requests
for modification of existing exemptions, requests for renewal of exemptions,
requests to be a party to existing exemptions and requests for emergency
exemptions. RSPA evaluates, and grants or denies these exemption
18
applications for new exemptions, modifications to exemptions and emergency
exemptions with the full coordination of the modal administration involved.
In 1987, RSPA received 1,448 applications for exemption actions
including emergency exemptions; granting 1,266, including 117 new exemptions,
51 emergency exemptions and 1,098 renewals, modifications, or parties to
existing exemptions. Of this number, FRA evaluated 106 applications for both
small and bulk packages of hazardous materials in addition to preparing three
requests for Emergency Exemptions for the transportation of hazardous
materials by rail. FHWA evaluated 245 affecting transportation by highway,
-
FAA evaluated 90 pertaining to transportation by air and the Coast Guard
evaluated 95 affecting transportation by vessel. In addition, the Coast
Guard approved 12 requests to authorize the shipment of military and Class A
commercial explosives in intermodal freight containers by vessel, and three
other requests relating to the handling or stowage of military or Class A
commercial explosives on board vessels; and issued four Letters of
Authorization allowing non-DOT specification portable tanks to be used to
transport combustible liquids by vessel. The total number of exemptions in
effect at the end of 1987 was 1,019.
Approvals
RSPA's responsibilities also extend to inspection and approval of non-
domestic cylinder manufacturers; the classification of new explosives;
coordinating the registration, testing, and approval functions formerly
delegated to the Bureau of Explosives of the Association of American
Railroads; conducting inspections and investigations in select areas; and
developing and issuing regulatory changes governing these activities.
Approval actions executed during 1987 follow:
Approval Activity in 1987
Number of Applications
Category
Received
Granted
Explosives Classification
3,941
4,385
Cylinder Retester
566
347
Cigarette Lighters/Packagings
56
55
Domestic Independent Inspection Agency Approvals
4
1
Repair/Rebullders
2
2
Foreign Approvals Manufactures
2
2
Foreign Approvals Inspections
63
50
Special Approvals
397
397
Summary of Registration Activity in 1987
Drum Reconditioners
22
22
Specification 35
4
4
Specification 39
6
7
Symobl Registration
36
36
*ANFO Registrations
3
3
. Blasting Agents
19
The foreign and domestic manufacture, repair, retest, and reuse of
cylinders used in the transportation of hazardous materials is strictly
regulated. Repair facilities must be approved by RSPA with the issuance of a
registration number which serves to identify that facility as authorized to
service cylinders to the extent of their authorization and in accordance with
the hazardous materials regulations. Seventeen companies outside the United
States reported producing DOT cylinders during 1987. With the total number
of manufacturers at 29, the number of manufacturers of DOT specification
cylinders outside the U.S. is almost three times the number of manufacturers
of high pressure cylinders in the domestic industry. Inspections were
- conducted in Argentina, Brazil, Mexico and Venezuela in 1987. Inspections
are scheduled for China, Mexico, Venezuela, Argentina, Brazil, England,
Germany, Italy, France, Canada, Israel and Singapore in 1988.
As the United States Competent Authority for all modes of transport,
RSPA is also assigned the responsibility for issuing competent authority
approvals and certifications under the ICAO Technical Instructions and the
International Maritime Organization's Dangerous Goods Code. These approvals
and certificates, required in certain instances under international
regulations to permit the shipment of hazardous materials, are of great
importance to U.S. shippers and carriers of hazardous materials. A total of
397 competent authority approvals and certifications were issued during the
year.
20
INSPECTION AND ENFORCEMENT
The Department of Transportation conducts an extensive inspection and
enforcement program to ensure industry compliance with hazardous materials
transportation regulations and to reduce the potential for catastrophic
accidents that may result from violations of the safety regulations.
Responsibility for the development of hazardous materials transportation
safety regulations is vested in RSPA whose primary responsibility is
hazardous materials transportation safety. Modal administrations, on the
other hand, are primarily responsible for carrier safety. Enforcement of
hazardous materials regulations is done in conjunction with those
responsibilities.
RSPA serves as the coordinator for Departmental policy. To achieve the
unified posture essential to an effective hazardous materials regulatory
program, RSPA convenes a bi-monthly intermodal meeting that provides a forum
for the exchange of information and the coordination of inspection and
enforcement activity. This modal collaboration and cooperation ensures
uniformity in the application of the hazardous materials regulations and
enhances the credibility of the Department's enforcement program.
In Calendar Year 1987, the Department's combined inspection resources
expended approximately 208.8 work years performing 125,820 inspections of
facilities, vehicles and vessels; investigating 418 incidents; initiating
1,319 penalty actions and collecting $1,466,943 in civil penalties. See
Tables I through III.
Table I
Hazardous Materials Inspectors-1987
Part-Time
Operating
Full-Time
Percent
Administration
Total
Inspectors
Inspectors
of Time
Work-Years
Work-Years
USCG
0
838
13.4
112.2
112.2
FAA
11
192
2.4
6.5
17.5
FHWA
0
257
8.6
22.1
22.1
FRA
34
62
15.0
9.0
48.0
104
5.0
5.0
RSPA
8
2
50.0
1.0
9.0
Totals
53
1,455
155.8
208.8
NOTE I: Information in this report pertains to transportation by vessel of both bulk and break bulk
hazardous materials.
NOTE II: The zero FHWA full-time inspectors displayed above reflects a conversion of nine regional
Hazardous Materials Specialists to State Program Specialists. FHWA is in the process of
reestablishing the Regional Hazardous Materials Manager positions.
21
Table II
Hazardous Materials Enforcement Actions
by Operating Administration
1986-1987
Enforcement Actions
FAA
FHWA
FRA
RSPA
USCG*
1986
1987
1986
1987
1986
1987
1986
1987
1986
1987
Criminal Cases Initiated
0
1
Criminal Cases Completed
0
1
Total Fines
$
0
:
Civil Penalty Actions
Initiated
85
112
137
NA
101
43
38
81
1,048
1,083
Civil Penalty Actions
Completed
55
45
72
65
53
43
22
36
153
272
Violations Noted and Corrected
Letters of Warning Issued
...
124
170
337
64
Total Civil Penalties
Collected
$
350,050
357,600
300,350
290,300
636,775
565,800
106,663
142,125
118,120
111,118
Average Penalty
$
6,364
7,964
4,172
4,466
12,015
13,158
4,848
3,948
772
848
. Starting in 1985 Coast Guard data presented above pertains to the transportation by vessel of both bulk and break bulk (packaged)
hazardous materials.
.. Five years confinment.
Table III
Hazardous Materials Inspections and Investigations by Mode
1986-1987
Category
FAA
FHWA
FRA
RSPA
USCG*
1986
1987
1986
1987
1986
1987
1986
1987
1986
1987
Operations/Facilities
Carriers
3,441
5,001
1,205
4,118
5,975
5,473
Shippers
897
389
3,080
2,529
138
166
Waterfront
3,976
4,547*
Container Manufacturers
63
93
52
38
Drum Reconditioners
13
5
Cylinder Retesters
31
34
Shipment Observations
246
233
Freight Forwarders
207
377
280
422
Packages/Shipping
Documents
11,048
14,644
Other
10
130
185
Vehicles/Vessels
Railroad Tank and Freight
Cars
76,763
72,367
22,840
29,028*
Vessels
1,080
..
Motor Vehicles
Accidents/Incidents
40
75
91
30
246
313
718
755
.
Data pertains to inspections and investigations of waterfront facilities handling both bulk and break bulk (packaged) hazardous
materials. Increase in number of vessels inspected is due to improved data collection methods.
..
Inspections of motor vehicles are carried out by state inspectors under MCSAP. 96,730 hazardous materials-carrying vehicles
were Inspected.
22
The Department has promoted and, in fact, heavily relies on our state
partners for highway enforcement of the hazardous materials transportation
rules. Fifty states and territories participated in the Motor Carrier Safety
Assistance Program (MCSAP) in 1987- 47 in the implementation phase and 3 in
development. Authorized under the Surface Transportation Assistance Act of
1982, MCSAP is a cooperative endeavor between the Federal Government and the
states to uniformly enforce Federal and state safety hazardous materials
regulations and rules applicable to commercial motor vehicles and their
drivers. Of the 1,000,044 vehicle inspections carried out by states under
MCSAP in 1987, 9.7 percent involved vehicles transporting hazardous
materials.
The primary focus of RSPA's inspection and enforcement program is
packaging in all its forms, e.g., plastic and steel drums, cylinders,
fiberboard boxes, etc., and related businesses such as independent
inspection, retesting, and reconditioning. In addition, RSPA expends much
time and effort inspecting shipments of hazardous materials at the shipper's
plant or the consolidator's dock, or somewhere in the transportation system.
Shipments are examined in detail for compliance not only with regard to
classification, marking, labeling, and documentation, but also for compliance
with packaging specifications and requirements. RSPA also purchases
containers on the open market and arranges testing to determine compliance.
In 1987, RSPA observed the 10th anniversary of its hazardous materials
inspection and enforcement program. Its staff of ten inspectors, an increase
of 3 over 1986, performed 661 inspections, initiated 81 civil penalty cases
and one compliance order case, issued 170 letters of warning, and collected
$142, 125 in penalties. This represents an increase over 1986 of 8 percent in
inspections conducted over 100 percent in penalty actions initiated, 33
percent in warning letters issued and 33 percent in penalties collected.
The varied coverage of the program is exemplified in the types of cases
initiated: 16 cases against container manufacturers of all types; 20 cases
involving shippers of general hazardous materials, including two foreign
companies; 12 cases against cylinder retesters; 12 cases involving carriers
and shippers of radioactive materials; three cases against independent
inspection agencies; two cases involving importers of hazardous materials and
one involving a freight forwarder.
In addition, RSPA initiated two enforcement programs in 1987 focusing on
incident reporting and validity of exemptions. Nine enforcement cases were
initiated against carriers who failed to file written incident reports
following unintentional releases of hazardous materials and seven cases were
initiated against companies continuing to operate under expired DOT
exemptions.
In 1987, the Office of Motor Carriers' field staff expended a total of
22 work-years investigating 30 incidents, conducting 4,507 audits of shippers
and motor carriers engaged in hazardous materials movements, including
radioactive materials movements. This activity resulted in the initiation of
enforcement cases and the imposition of civil penalties of approximately
$290,300.
23
The OMC field staff continued its emphasis on auditing manufacturers of
DOT specification cargo tanks. Ten such audits were done in 1987. This
activity involved on-site inspection of production facilities, detailed
audits of the manufacturers' records, and technical examination of drawings,
calculations, and test reports to evaluate the manufacturers's degree of
compliance with the HMR. Recommendations for correcting violations detected
were offered to the manufacturer.
Within the FAA, hazardous materials inspections/surveillance activities
are conducted by civil aviation security inspectors in conjunction with
-regularly scheduled security inspections of air carriers and airports. At a
minimum, inspections are conducted of all air carriers, both U.S. and
foreign, where it is determined that the air carrier (passenger or cargo)
regularly accepts and transports or handles hazardous materials. These
inspections are conducted frequently based on a review and analysis of prior
hazardous materials shipments, incident experience and violation history.
In order to determine compliance effectiveness and ensure that freight
forwarders and shippers meet their basic responsibilities in the shipment of
hazardous materials by air, the FAA is continuing inspections efforts at the
major air carrier facilities at major airports. These locations are
considered collection points for shipments originating from many freight
forwarders and shippers and are where these shipments first come under the
FAA jurisdiction. Here the FAA participates in jointly coordinated
inspection programs with local Bureau of Motor Carrier Safety inspectors to
ensure that those commodities being transported to air carrier facilities are
done so under the provisions of the pertinent regulations.
The hazardous materials enforcement program is carried out by the Office
of Civil Aviation Security and includes participation in the Flight Standards
National Aviation Safety Inspection Program (NASIP), which calls for special
in-depth inspections of Federal Aviation Regulations (FAR) Parts 121 and 135
air carriers and other aviation-related organizations. In the past year,
17 civil aviation security inspectors have been provided as hazardous
materials representatives on 16 NASIP inspections. A total of 19 hazardous
materials enforcement cases were initiated as a result of these inspections.
Two FAA Washington headquarters. and nine regional positions are assigned
full-time hazardous materials program management and compliance and
enforcement duties. In addition, there are approximately 192 inspectors who
conduct hazardous materials inspections along with other civil aviation
security duties. A total of 17.5 work years were expended by FAA in the
hazardous materials compliance and enforcement program during 1987. The
5,378 inspections conducted during the year represents an increase of
approximately 47 percent over the number of inspections conducted during
1986. In the course of these 5,378 inspections, a total of 14,644 individual
hazardous materials shipments and associated shipping papers were inspected
resulting in 411 hazardous materials violations being detected. The
investigation of 75 hazardous materials incidents resulted in the detection
of an additional 73 violations. The one criminal case concluded in 1987
resulted in a sentence of confinement for five years for the defendant.
24
Based on a 1986 survey of import and export shipments in intermodal
freight containers passing through U.S. marine terminals, the Coast Guard in
1987, began development of a comprehensive enforcement program for packaged
hazardous materials. Field research has demonstrated the need for close
coordination of this program with the U.S. Customs Service at the
headquarters and field level, as well as communication with cognizant state
police and fire departments. The Coast Guard and Customs both examine cargo
at marine terminals, and care must be taken in developing this program to
encourage sharing of information obtained during such examination as well as
to avoid practices which might cause conflicts in the exercise of each
agency's responsibilities. In the course of field inspections, trends of
non-compliance became evident in certain industries and as a result, the
Coast Guard was involved in various enforcement programs targeting specific
commodities, including intermodal shipments of lead-acid batteries and
fireworks imports.
Inspection of containerized shipments of lead-acid batteries resulted in
the detention of freight containers which contained improperly prepared
shipments of used automobile and motorcycle batteries. None were placarded
or properly dunnaged or manifested, and many of the batteries were cracked
and leaking. All were consigned to destinations in the Far East. In
addition to imposing civil penalties for such violations, the Coast Guard
continued to work with the shippers and the metals recycling industry in an
effort to improve future regulatory compliance and preclude recurrence of
these unsafe practices. This situation presents several dangers in the
transportation system. Operators of vessels and waterfront facilities are
not afforded the opportunity to properly segregate these corrosives from
incompatible cargoes, and response personnel may take action during an
emergency they might not otherwise have taken had they been aware of the
presence of corrosive liquids. During the highway segment of the container's
transit it may go through tunnels where hazardous materials are otherwise
prohibited. Additionally, U.S. battery manufacturers who go to significant
expense to comply with environmental and safety regulations are placed at a
financial disadvantage by having to compete with firms who realize
substantial savings in transportation costs by circumventing those same
requirements.
The Coast Guard, RSPA and the Maryland Port Administration participated
in a U.S. Customs Service organized enforcement operation in Baltimore, MD,
in 1987, targeting containerized import shipments of fireworks and other
explosives. Customs became aware that several foreign manufacturers were
misrepresenting their shipments in an apparent effort to reduce their U.S.
import duty. Early in the operation it became evident that non-compliance
was widespread. Forty-six containers were inspected; 31 of these were
unloaded, comprising over 180 tons of fireworks, and 17 were either seized by
Customs or detained by the Coast Guard until they were brought into
compliance. Ten civil penalty cases have been initiated by the Coast Guard
in addition to those by Customs and RSPA. Not only were Customs-required
import declarations being improperly prepared and shipments falsely
represented, but DOT-required shipping papers, labels and placards were
improper and several explosives were not RSPA approved, as required by
regulation. Some shipments have simply not been tested and approved; in
25
other cases, manufacturers were having one commodity approved, then using
that approval number on a variety of products, a practice strictly contrary
to the intent and letter of the regulations. During the second half of 1987,
over 15,000 tons of fireworks were imported into the United States, the vast
majority from the Far East. If improper and potentially unsafe shipments are
not interdicted at the port of entry, they enter the transportation system
and are carried by truck or rail to destinations all over the United States.
The Coast Guard will continue to work with Customs and RSPA in attempting to
improve the compliance record of the fireworks industry and reduce this
significant threat by inspecting and detaining improper shipments necessary.
Thousands of tons of packaged hazardous materials pass through U.S.
ports every day on U.S. and foreign flag freight vessels. Each of these
vessels is examined thoroughly by the Coast Guard at least once each year,
and cargo transfer operations are monitored at least twice a year.
The Coast Guard continued to provide assistance to the Marine Corps in
the loading and unloading of hazardous materials of different hazard classes,
including approximately 1 million net pounds of military explosives per ship,
on Military Prepositioning Ships (MPS) during 1987. These operations are
pursuant to the vessels' biennial maintenance periods. These commercial
vessels, under charter to the U.S. Navy's Military Sealift Command, are
floating warehouses intended to provide all provisions necessary to supply
Marine Corps landing forces for 30 days. Complex loading, stowage and
segregation plans are required by regulation to be approved by the Coast
Guard Captain of the Port for each ship. Coast Guard Headquarters
representatives visited the Port of Jacksonville, Florida to provide
assistance monitoring loading and reloading operations on each ship in 1987.
The Federal Railroad Administration (FRA) currently has on board 34
full-time hazardous materials inspectors. Their ranks are increased by
inspectors from other safety disciplines 62 operating practices inspectors
and 104 motive power and equipment inspectors -- who devote 15 percent and 5
percent of their time to hazardous material movements, respectively. To
monitor industry compliance with the Hazardous Materials Regulations, FRA
conducts hazardous materials inspections at rail facilities,
shipper/consignee plants, freight forwarder facilities, and package
manufacturing facilities.
At rail facilities, FRA inspectors evaluate carrier compliance with
requirements governing train placement, placarding, equipment standards and
proper documentation (shipping papers, notices, and train consists). They
also determine if carriers have given proper notice to individual train and
engine crews who are responsible for transporting these regulated
commodities. Shipper/consignee inspections are conducted to monitor
compliance with regulations concerning shipping papers, labeling, packaging,
marking, and loading and unloading of tank cars. At freight forwarder
facilities, FRA inspectors evaluate compliance with the regulations
concerning documentation required for hazardous materials movements in
Trailer-on-Flatcar (TOFC) and Container-on-Flatcar (COFC) service. FRA
increased its freight forwarder inspections 51 percent from 1986 to 1987, as
a response to increased TOFC and COFC shipments of hazardous materials. The
26
facilities where hazardous materials packages are manufactured are inspected
to evaluate if DOT specification packages have been manufactured, fabricated,
marked, maintained, reconditioned, repaired, or retested in accordance with
the HMR.
Other duties of FRA inspectors include investigations of rail accidents
and incidents affecting the public, as in hazardous materials spills,
leakages, and emergency evacuation situations. In addition, because of a
growing number of injuries to railroad operating employees resulting from
improperly maintained and secured appurtenances (tank car closures - manways,
valve plugs, gaskets, etc.), FRA inspects shippers facilities on a continuing
basis to ensure that proper maintenance and car preparation practices are
followed before any hazardous materials are shipped.
In general, the violations most frequently noted by FRA inspectors and
the violations for which civil penalties were most frequently sought were
improperly secured hazardous materials tank cars and improper placement of
placarded cars in a train consist.
In 1987, FRA with the cooperation of the Coast Guard, FHWA, United
States Customs, New Jersey Department of Transportation and New Jersey State
Police conducted a mini-assessment of freight forwarders and bulk chemical
shippers in the Newark, New Jersey and New York area. A total of 29 freight
forwarder operations (10 marine terminals and 19 import/export agents and
freight forwarders), 26 bulk chemical manufacturers and two rail carriers
that service the area were inspected during a two-week period. Seventy-eight
percent of the import/export agents and freight forwarders were found not to
be in full compliance with existing regulations. Sixty-one percent of the
bulk chemical shippers were found to be below an acceptable level of
compliance and both rail carriers were also found to be below an acceptable
level of compliance.
The deficiencies most frequently encountered included:
- Improper DOT shipping name and classification of commodities.
- Omission of the DOT hazard classification and placard notation
for transport vehicles going in either TOFC or COFC service, by
rail.
- Illegible placards.
- Failure to properly secure appurtenances (dome covers, valve
plugs, etc.).
- Accepting improperly prepared documentation.
- Failure to inspect tank cars.
FRA intends to conduct more mini-assessments in geographical areas that
have a high concentration of hazardous materials movements. An assessment of
the Portland, Oregon area is planned for 1988 to include intermodal movements
of hazardous materials in containers and intermodal (IM) portable tanks
traveling in either TOFC or COFC service.
FRA continues to monitor spent nuclear fuel shipments from point of
origin to final destination. Each spent nuclear fuel shipment is inspected
prior to being offered for rail transportation by FRA personnel. In
27
addition, FRA biannually inspects the route to assure that the track, signal
systems and railroad operating practices comply with Federal safety
standards.
28
INTERNATIONAL ACTIVITIES
The United States participates in the work of international standard-
setting organizations in order to promote a worldwide system of consistent
modal and regional transportation safety requirements. The primary' U.S.
objective is to ensure, as far as practicable, that shipments of hazardous
materials may move freely and safely among the various modes of transport and
regions of the world. An active U.S. role in the development of
international standards is essential to the economic interests of the
domestic hazardous materials industry. Adoption of transportation safety
- standards by other nations and regional bodies throughout the world has a
direct impact on U.S. shippers and carriers of exports, and inequitable or
incompatible international requirements can have a profoundly negative impact
on an industry which has consistently earned a balance of trade surplus.
Such impacts could, therefore, affect the overall economy of the United
States.
In 1987, as in the past, the Department continued to support a uniform,
global approach to the safe transportation of hazardous materials through
participation in the work of several international organizations:
1. The Committee of Experts on the Transport of Dangerous Goods of the
United Nations Economic and Social Council (ECOSOC), including the
Committee's two subsidiary bodies:
(a) The Group of Experts on Explosives, and
(b) The Group of Rapporteurs;
2.
The Subcommittee on the Carriage of Dangerous Goods of the
International Maritime Organization (IMO);
3. The Dangerous Goods Panel of the International Civil Aviation
Organization (ICAO)
4. The Group of Experts on the Transport of Dangerous Goods of the United
Nations Economic Commission for Europe (ECE);
5. The International Atomic Energy Agency (IAEA) ; and,
6. The Highway Operations Committee of the Pan American Highway Congress.
A summary of the Department's participation in the activities of each
organization during 1987 is provided below:
The ECOSOC Committee of Experts on the Transport of Dangerous Goods
This Committee is the focal point of international activity regarding
all transportation of packaged hazardous materials (except radioactive
materials). It meets biennially to consider the work of its two subsidiary
bodies, the Group of Experts on Explosives and the Group of Rapporteurs.
RSPA is the agency charged by the Department of State to represent the United
States on each of these committees. During 1987, the Group of Experts on
29
Explosives and the Group of Rapporteurs each met once. The results of their
work for the 1987-88 biennium will be considered by the Committee of Experts
at its Fifteenth Session in December of 1988. Those items adopted by the
Committee will then be reported to ECOSOC, which is responsible for taking
final action to include these decisions in the United Nations Recommendations
on the Transport of Dangerous Goods, the primary body of international
standards on the transport of hazardous materials.
The Committee's 1987-88 work program for its two subsidiary groups
covered a wide variety of topics, including several of great interest to the
United States. Among these were the following:
(a)
Adoption of tests and criteria for classification of highly
insensitive explosives articles. At its Fourteenth Session, the
Committee of Experts adopted the U.S. proposal to amend the
definition of Division 1.5 to include highly insensitive explosives
articles as well as substances. The Committee then invited the
United States to propose detailed tests and criteria for
classification of such articles. The U.S. proposal was considered
by the Group of Experts on Explosives in August and the United
States was invited to submit a revised proposal for consideration
at the next session. This issue is of great importance to the
Department of Defense (DOD), which has invested considerable
resources in developing a new generation of highly insensitive
explosives in order to improve the safety of munitions transport
and storage. Lacking international recognition of the unique
nature of these explosives articles, the DOD has had to ship these
articles under much more stringent packing and stowage requirements
than is warranted by their relatively low risk. This, in turn, has
increased shipping costs while reducing the availability of ports
for off-loading. While the immediate benefit of the new
classification will accrue to the military, many experts believe
that the availability of this new classification would encourage
the commercial development of such highly insensitive explosives
articles and would, therefore, lead to an overall enhancement in
the safe transport of explosives.
(b)
Classification of Gases. The U.N. Recommendations lack a
single set of classification criteria for materials of Class 2,
i.e. gases. These materials present different types of risks in
transport which should be addressed in the body of the
Recommendations. In 1987 the United States presented a proposal,
based on its ongoing rulemaking proposal (Docket No. HM-181), to
establish three divisions in Class 2. This would categorize Class
2 materials as flammable, compressed or poisonous gases. While
opinions differed on the preferred number of divisions, there was
general agreement among the Rapporteurs on the need to adopt
defining criteria. Accordingly, the United States was invited to
submit a more detailed proposal for consideration at the next
session.
30
(c)
Classification of liquid oxidizers. The Fourteenth Session of
the Committee of Experts adopted tests and criteria for
classification of solid oxidizers, but was unable to reach
agreement on provisions for liquids. In 1987, the United States
presented a proposal based on the test protocol which has been in
domestic use for many years. Technical opinions differed on the
relative merits of including such a test in the Recommendations,
but the United States was invited to submit a revised proposal
reflecting the results of the discussion at the next session of the
Rapporteurs.
International Maritime Organization (IMO)
The International Maritime Organization (IMO) is a specialized agency of
the United Nations concerned primarily with the promotion of safety in
shipping and the prevention of marine pollution from ships. IMO facilitates
cooperation among governments on technical matters affecting marine safety
and pollution prevention through the exchange of information under the
auspices of its committees and the adoption of international agreements. The
Department participates in the work of IMO through the State Department's
Shipping Coordinating Committee. The Coast Guard co-chairs that committee,
which coordinates all U.S. input to IMO, provides technical expertise for
U.S. delegation to IMO, and with RSPA represents the Department on the IMO's
sub Committee on Dangerous Goods (CDG). Technical matters concerning safety
and prevention of pollution from hazardous materials are handled within four
subcommittees: Subcommittee on Bulk Chemicals (BCH), Subcommittee on
Carriage of Dangerous Goods (CDG), Subcommittee on Containers and Cargoes
(BC), and Subcommittee on Fire Protection (FP). International requirements
developed by the technical subcommittees are then approved by the parent
committees: the Maritime Safety Committee (MSC) and the Marine Environment
Protection Committee (MEPC). With respect to pollution prevention measures
relating to bulk oil transportation, requirements are developed in the MEPC
without being considered by a subcommittee.
The CDG Subcommittee publishes and maintains the International Maritime
Dangerous Goods (IMDG) Code. This code is recognized as the worldwide
standard for the transportation of packaged hazardous materials by vessel.
U.S. regulations governing the transportation of hazardous materials
incorporate substantial portions of the IMDG code by reference. At its April
1987 meeting the U.S. delegation presented 13 position papers on diverse
subjects including (a) a "Grandfather" provision covering all military
dangerous goods; (b) development of provisions for the implementation of
MARPOL Annex III regulations for the prevention of marine pollution by
packaged harmful substances; and (c) establishment of a marine pollution
marking for packagings.
The CDG Subcommittee also continued work on the complete revision of
Class 7 (Radioactive Materials) to align the IMDG Code requirements with
those contained in the 1985 International Atomic Energy Agency Recommendation
31
and Class 1 (Explosives). It is anticipated that revision of these two major
sections of the IMDG Code will be completed in 1988. Other actions by the
subcommittee included:
Adoption of selection criteria for mixtures and solutions of
Annex III marine pollutants.
Amendments to the publication "Emergency Procedures for Ships
Carrying Dangerous Goods" and the Medical First Aid Guide (MFAG)
concerning goods in "not otherwise specified" (n.o.s.) entries, and
emergency twenty-four hour medical advice telephone numbers.
Adoption of the UN standards for Flexible Intermediate Bulk
Containers (FIBCs), and development of a list for substances
specifically permitted for transport in FIBCs.
The United States has taken the initiative on development of provisions
for the implementation of MARPOL Annex III. The purpose of Annex III is to
protect the marine environment from accidental release of marine pollutants
in packaged form. The Annex establishes detailed requirements concerning
packaging, marking/labeling, documentation, stowage and if necessary quantity
limitation for preventing or minimizing pollution of the marine environment.
Any loss of marine pollutants overboard must be reported under the Annex.
The IMDG code schedules were revised in order to reflect the provisions
dealing with those packaged marine pollutants thus far identified which are
also dangerous goods, as well as for the new Class 9 entries listed under the
new United Nations serials for Environmentally Hazardous Substances, n.o.s.
The reporting requirements contained in Protocol I to MARPOL Annex III became
effective in April 1987. The working group will continue its protocols to
solicit information on the capabilities of packages containing marine
pollutants to endure submersion.
MARPOL Annex III has not entered into force internationally, but will
enter into force 12 months after the date on which not less than 15
countries, representing 50 percent of the gross tonnage of the world's
merchant shipping, have become party to it. If the United States which
represents 5 percent of that tonnage ratifies, the required 50 percent would
be met, thereby bringing the Annex into force worldwide.
With strong U.S. leadership, the MEPC and the CDG Subcommittee have
resolved most of the key implementing issues. The Coast Guard is now
prepared to move toward domestic ratification of Annex III. At an
interagency meeting chaired by the Coast Guard in December 1987,
representatives from RSPA, the State Department, the Environmental Protection
Agency and others discussed the mechanics of ratification and effects on
various statutes and regulations. RSPA and the Coast Guard will be
coordinating their efforts on ratification and implementation of Annex III.
It is expected that this may take two years.
32
International Civil Aviation Organization (ICAO)
The Dangerous Goods Panel (DGP) of the International Civil Aviation
Organization is responsible for periodic updating of Annex 18 to the
Convention on International Civil Aviation (which prescribes basic
requirements for the safe transportation of dangerous goods by air). and its
supporting Technical Instructions (which provide the detailed requirements
necessary to implement Annex 18). RSPA provided the panel member for the
United States. In 1987, the DGP updated the Technical Instructions to
provide appropriate measures for the safe transport of new chemicals entering
into the marketplace; to address potential safety hazards; to incorporate
advancements in packaging and air transport technology; and to address issues
that result in the imposition of unwarranted economic hardships on shippers
and carriers. At the same time, the DGP continued work on development of
revisions to the Technical Instructions to conform to the latest revised
standards of the International Atomic Energy Agency for the safe
transportation of radioactive materials.
The ECE Group of Experts on the Transport of Dangerous Goods
The Group of Experts on the Transport of Dangerous Goods of the U.N.
Economic Commission for Europe (ECE) is responsible for updating and revising
the European Agreement Concerning the Carriage of Dangerous Goods by Road
(ADR). Although the ADR is a European Convention, it is administered through
a duly constituted committee of the United Nations and, for this reason, the
United States (represented by RSPA) has full voting rights with respect to
the ADR. At least twice each year, the ADR meets jointly with the
organization responsible for updating the International Regulations
Concerning the Carriage of Dangerous Goods by Rail (RID) to ensure
consistency between the two sets of regulations. Although these are European
conventions, they are of interest to the United States because of the direct
impact of their requirements on shipments of hazardous materials from the
United States. Furthermore, many members of ADR and RID, who are also
members of the ECOSOC Committee of Experts on the Transport of Dangerous
Goods, have demonstrated a tendency to favor close alignment of the
international standards with those previously adopted by RID/ADR. The
following matters of particular interest to the United States were discussed
at the two joint RID/ADR meetings held in 1987:
(a) Harmonization of the RID/ADR provisions for the transport of
explosives with those of the U.N. Committee of Experts on the
Transport of Dangerous Goods. This issue is of particular interest
to the Department of Defense because it will have a direct impact
on the movement of military explosives within Europe. In 1987, the
joint meeting agreed to adopt a grandfather clause which would
allow goods packaged prior to the effective date of the U.N.
packaging rules to continue to be transported in international
commerce.
(b) Harmonization of the RID/ADR provisions for the transport of
radioactive materials with those of the International Atomic Energy
Agency and the U.N. Committee of Experts on the Transport of
33
Dangerous Goods. This effort parallels the work of other modal
organizations to implement the latest revised IAEA standards by
January 1, 1990. Minor amendments, however, could have significant
impacts on non-European transporters and the United States has
followed these efforts closely to ensure that such differences do
not develop.
International Atomic Energy Agency (IAEA)
The International Atomic Energy Agency (IAEA) is an intergovernmental
body chartered to foster the peaceful contribution of nuclear energy to
mankind. A very necessary element in the application of nuclear technology
is the transportation of nuclear materials and, consequently, the IAEA
developed a regulatory system to help ensure the safe international
transportation of such materials. RSPA represents the United States with
respect to transportation and serves as the Competent Authority of the United
States to both governmental and private parties involved in nuclear
transportation, issues Certificates of Competent Authority relating to
package and shipment approvals required by the IAEA transportation
regulations, and provides technical expertise to the IAEA.
In 1987, RSPA continued to participate as a member of the Standing
Advisory Group for the Safe Transport of Radioactive Materials (SAGSTRAM),
the primary group advising the IAEA Director-General on transportation
activities and initiatives involving radioactive materials. Knowledge of the
status of IAEA activities is crucial to ensuring appropriate and timely U.S.
input to maintain compatibility of domestic and international regulations.
RSPA participation in SAGSTRAM ensures that the United States is able to
promote its goal of harmonization of international regulations affecting the
transport of radioactive materials.
Among the topics considered at the 1987 SAGSTRAM meeting were: (1) the
implementation of the IAEA Transport Regulations (Safety Series No. 6), and
(2) the evaluation of the packaging standards for air transport of plutonium.
As a result of the meeting, the IAEA will continue its process of updating
and revising Safety Series No. 6 for uniform application of radioactive
materials transportation regulations worldwide. The evaluation of packaging
standards for air transport of plutonium is expected to involve consideration
of the standards adopted by the U.S. Nuclear Regulatory Commission.
Pan American Highway Congress
The Pan American Highway Congress has been in existence for 60 years.
Its original purpose was to propose the integration of the Americas by the
development of a highway system which connected all major cities. The
current work of the Congress has been to promote regional highway
transportation improvements and the sharing of technology. In this latter
capacity, the Congress has initiated consideration of the safety implications
of hazardous materials transportation.
At the 15th Congress, held in October of 1986, the Highway Operations
34
Committee established a working group to study regulations for transporting
dangerous commodities and specifically invited the United States to present a
paper on the transportation of hazardous wastes. The Department's Federal
Highway Administration represents the United States at these meetings and,
upon receiving this request, invited RSPA to participate in the working group
on the transportation of dangerous commodities. This interest in hazardous
materials transportation is encouraging both from the standpoint of overall
safety and as an indication of potential for expanding the membership of the
ECOSOC Committee of Experts on the Transport of Dangerous Goods to achieve
greater geographic representation than is currently the case.
The discussions of the working group on hazardous materials
transportation were quite productive and the Congress adopted a resolution
calling for the establishment of a working group to produce a "Pan American
Manual of Standards for Automotive Transportation of Dangerous Goods". An
informal session of the working group met in Caracas in late November to
consider the form of a recommendation to the Highway Operations Committee.
It is expected that this issue will be included in future Committee work
programs.
35
RSPA Actions to Recognize International Standards
The Department's active involvement in developing international
standards for the transportation of dangerous goods would be of limited value
if steps were not taken to recognize these standards within the framework of
the domestic regulatory program. As more and more industrialized nations
move toward the implementation of these international standards, U.S.
industries engaged in the international sale and transportation of hazardous
materials may find themselves having to comply with differing domestic and
international requirements. It becomes incumbent on the Department,
therefore, to recognize these standards through the hazardous materials
regulations so as to minimize the economic burden that compliance with such
dual standards would impose on these industries. Furthermore, the General
Agreement on Trade and Tariffs) (GATT) imposes treaty obligations on the U.S.
to take steps to eliminate regulations which constitute non-tariff trade
barriers. Similarly, under Title IV of the Trade Agreements Act of 1979 (19
U.S.C. 2532) the Department has a statutory mandate to incorporate
international standards, particularly those which are performance-oriented,
to the maximum extent consistent with safety. For these reasons, RSPA has
long been concerned with implementing these international standards through
the rulemaking process.
In May RSPA published a notice of proposed rulemaking (NPRM) that
proposes to align the hazardous materials regulations with the United Nations
Recommendations on the Transport of Dangerous Goods and the ICAO Technical
Instructions in the areas of hazard classification, packaging and hazard
communication. This rulemaking generated an extremely high level of public
interest and the period for receipt of public comments had not closed by the
end of 1987.
Conclusion
Considerable industry interest in the Department's involvement in these
international organizations is stimulated, in large part, by the impact that
the standards issued by these organizations have on U.S. industries involved
in the international sale and distribution of hazardous materials. The RSPA
hosts periodic public meetings to inform industry of work underway within
these organizations and a number of U.S. businesses have approached RSPA with
requests to initiate particular actions with various international
organizations, or for assistance in obtaining approvals or information from
foreign governments.
Continued participation by the Department in these standards-setting
bodies is absolutely essential. Only by maintaining its active involvement
can the Department ensure that the requirements developed by these
international bodies promote safety in the international transportation of
hazardous materials, without impeding their free movement by creating
artificial trade barriers.
36
TRAINING AND INFORMATION DISSEMINATION
Training and education are an integral part of the Department's
regulatory program and of its responsibilities for emergency response to
hazardous materials spills in transportation. To promote compliance with the
hazardous materials regulations, the Department sponsors a number of training
and information dissemination activities designed to familiarize industry
personnel with the requirements of the regulations and to educate government
inspectors in enforcement procedures. The sources for this training are:
(1) the Department's Transportation Safety Institute (TSI) located in
Oklahoma City, OK which receives financial and technical support from RSPA
-
and the operating administrations to provide instruction on individual modal,
as well as cross-modal, regulatory responsibilities; and (2) RSPA in
Washington, D.C., which offers a wide array of training materials packages
and job aids to all segments of the hazardous materials enforcement and
emergency response communities.
During 1987, TSI conducted a total of 24 classes in various facets of
hazardous materials regulation enforcement including four on Cargo Tank
Roadside Inspection, one Train-the-Trainer, 17 on basic Hazardous Materials
Compliance and Enforcement and two on the Safe and Legal Transport of
Radiopharmaceuticals and Labeled Compounds. Other than the last course which
was developed solely for private industry, the primary beneficiary of the
training conducted by TSI has been the states. Of the 768 persons receiving
training during the year, 483, or 63 percent, were state and local government
personnel.
One basic and four advanced classes in air transportation of Hazardous
Materials were conducted at the Mike Monroney Aeronautical Center, Oklahoma
City, Oklahoma. Twenty-one new inspectors received basic training, and 68
inspectors received recurrent training, Regional personnel conducted 5
training sessions for 41 FAA inspectors and participated in 11
seminar/training sessions attended by 444 persons, including operators,
freight forwarders, shippers, and other aviation industries affected by the
Hazardous Materials Regulations.
The FHWA's Office of Motor Carriers conducted or participated in more
than 566 seminars or meetings (including hazardous materials refresher
courses) covering portions of the Motor Carrier Safety Regulations and the
Hazardous Materials Regulations. These seminars and training activities,
attended by personnel from the motor carrier industry, shippers of hazardous
materials, labor unions, and state/local governments, covered instructions in
methods and procedures necessary to achieve compliance with applicable
Federal regulations.
The FRA field staff conducted: 88 seminars, attended by 2,487 fire and
emergency response personnel; 89 rail carrier seminars, attended by 1,528
carrier employees and officials; and two courses on rail transportation of
hazardous materials, attended by 50 FRA and state enforcement inspectors.
37
Information Dissemination
The Department is firmly committed to the concept of safeguarding the
public from the dangers incidental to the transportation of hazardous
materials. This commitment is reflected in the continuing revision, update,
and issuance of publications that keep the regulated community, as well as
the regulators, informed concerning hazardous materials regulations and
issues. In addition to sponsoring classroom training, the Department
provides training and information materials for use by the regulated public
(shippers, carriers, freight forwarders), emergency responders, and
enforcement personnel. These aids are in the form of a variety of pamphlets,
charts, posters, fact sheets, newsletters, and other handout materials
offered in response to an increasing number of public inquiries for
information, clarification, or interpretation of various aspects of the
hazardous materials regulations.
RSPA supplies over one million pieces annually of 50 different items of
hazardous materials training/information publications in response to
approximately 13,000 requests from a diverse population. These requests come
from fire departments, police departments, sheriffs, civil defense/emergency
management agencies, corporations and individual businesses, universities and
colleges, and other Federal, state, and local government agencies. To ensure
that we provide the hazardous materials transportation community with the
most accurate and timely information, RSPA undertook an intense update and
revision of its library of guidance and educational materials in 1987. This
project will continue through 1988.
Over the years, RSPA has developed and published a number of emergency
response guidance documents that receive wide distribution in the emergency
response community. By far, the most widely distributed of these is the
Emergency Response Guidebook. Since its initial publication in 1980,
approximately 2 1/2 million copies have been printed and distributed at an
approximate cost of $1.8 million. It lists all hazardous materials regulated
by the Department of Transportation along with suggested initial response
actions in the event of an incident (spill, explosion, fire) involving these
products and is made available free to first responders--police, fire and
their emergency response personnel. Updated every three years to reflect the
introduction of new hazardous products into the market and/or new and
improved methods of handling these products in an emergency, it was
completely revised in 1987. A newly introduced distribution system utilizing
designated state coordinators as distribution points has proven to be faster
and more effective in getting the Guidebook to the target audience. The
Guidebook has been translated, reproduced and distributed by Mexico, Sweden,
and Japan. Saudi Arabia is now in the process of translating it into Arabic.
RSPA and the Federal Emergency Management Agency established a
computerized Hazardous Materials Information Exchange (HMIX) to improve the
dissemination of timely information on hazardous materials and emergency
response training. The HMIX allows users to receive and exchange
information regarding the preparation for, and prevention and mitigation of
hazardous materials incidents in two ways personal computer or by calling
a toll-free number, 1-800-752-6367.
38
With a personal computer, users can reach an electronic "bulletin board"
containing information on Federal and state hazardous materials and emergency
response training courses, instructional materials and literature listings,
private sector activities, hazardous materials regulations updates, official
interpretations, and other relevant information. The bulletin board is
designed for two-way communication as well. The toll-free number provides
on-line telephone assistance and information to those individuals without
computer capabilities. Between its inception in January 1987 and December
1987, the user level increased to almost 1,400. By far, the most active
users are at the local level which indicates that we are meeting one of our
major goals, and that is to get valuable hazardous material and emergency
response information to local planners and responders.
The Coast Guard pursued numerous public education efforts in the area of
hazardous materials transportation. The following articles on hazardous
materials were published in the Coast Guard's Proceedings of the Marine
Safety Council, a magazine which receives wide distribution in the Coast
Guard and the maritime industry:
-
"Barge Transportation of Radioactive Materials"
- "The International Maritime Organization (and What the Coast Guard Does
There)"
-
"SOLAS Working Group on the Carriage of Dangerous Goods and the IMDG
Code"
- "Fire and Explosion on the Letetia Lykes"
- "CHRIS? Who's CHRIS?"
In addition, each issue of Proceedings featured a "Chemical of the Month"
giving the properties and hazards associated with various hazardous
materials. The Coast Guard was also featured in several articles in the
international publication, Hazardous Cargo Bulletin.
39
Technology Research
The Department's hazardous materials research and technology program
provides technical support for development, modification, and interpretation
of the hazardous materials regulations and enforcement activities. Research
is conducted to find answers to special problems or to address unique safety
concerns where current regulations may not fully provide for technological
advances and to evaluate the feasibility of enforcement action.
Transportation of hazardous materials is a multimodal activity, therefore,
the Department's research and technology initiatives span all modes, address
a multiplicity of issues that reflect individual modal commitments to
- improving safety and efficiency, and run the gamut from routine performance
testing to the more complex applied research programs. Highlights of the
Department's research activities carried out through its operating
administrations during 1987 follow.
(1) Evaluation of Toxicity Hazards in Transportation-Phase II.
This phase involved an investigation and evaluation of criteria for the
packaging of bulk quantities of liquid and gaseous materials which are
toxic by inhalation and considered three major areas: (1) development of
design criteria for bulk packagings based on performance criteria for
accidents; (2) development of a basic design methodology for typical
rail tank cars, cargo tanks and portable tanks that will analytically
pass the performance criteria; and (3) evaluation of the effect of the
quantity spilled and method of spill for various representative groups
of liquids and gases toxic by inhalation. Results evolving from this
phase include:
(a) Of five abnormal environments identified for both highway
and rail transportation impact, puncture, fire,
immersion and crush the first three were judged to be
significant contributors to the likelihood of packaging
failure. The study recommended that packagings for
materials toxic by inhalation be subjected to a
sequential test program of a drop, puncture and thermal
test.
(b) A design methodology was developed for bulk packagings
that will analytically pass the established performance
criteria.
(c) Establishment of the concept of "Quantity of Concern" for
the transportation of materials toxic by inhalation. The
quantity of concern is the amount of material that, if
spilled or released, has the potential to produce a
downwind vapor concentration that may be dangerous to
individuals. Formulas were developed to help estimate
the quantity of concern based on a material's physical
properties, its toxicity and vapor pressure. The results
of this work shows that the quantity of concern is much
smaller than bulk quantities now transported. It is
concluded that packaging integrity and accident
survivability characteristics are central to the safe
transportation of highly toxic materials.
40
(2) Evaluation of Cracking in Aluminum Cylinders. Examination of
a group of cylinders to determine the extent of cracking and to assess
the significance of such cracking resulted in the recommendation that:
additional inspections be made of cylinders that have been in service to
determine if service pressure, time of use and commodity carried have an
effect on the cracking; and a careful visual inspection be performed
during the required periodic retest. RSPA published a safety advisory
and Advance Notice of Proposed Rulemaking in July 1987 that addressed
this problem.
(3) Improved Design, Production, and Requalification Tests for Gas
Cylinders Fabricated from High Strength Steels, With millions of high
pressure gas cylinders in service in the nation's factories, hospitals,
and homes, the use of high pressure cylinders represents one of the
public's greatest exposures to hazardous materials. An industry trend
towards the use of higher strength materials to reduce cylinder weight
and thereby gain substantial productivity increases, has made necessary
the development of design, production, and requalification tests to
verify the safety of these cylinders. Preliminary work related to the
development of such tests has brought into question the validity of
production and requalification tests used for present DOT Specification
cylinders-- thereby amplifying the critical need for the development of
improved design, production and requalification tests.
(4) Development of Definition and Test Method for Flammable Gas-
Phase I. This phase of the study involves a comprehensive literature
survey on the definition and test methods for classification of
flammable gas. Publications from various governmental, international,
foreign and private sources were examined. This study will provide RSPA
with specific recommendations with regard to the definition of flammable
gas and proposals for further work, if necessary, to develop a suitable
test method for classification of flammable gas. The results of this
study will be used to support RSPA's rulemaking efforts on HM-181.
(5) Development of Test Criteria for Evaluating Detonation,
Fragmentation and Radiant Heat Hazards of Explosives. One new task was
added to this project to evaluate projection hazard criteria for certain
Class C explosive devices. Results obtained so far indicate there are
some deficiencies in the U.N. scheme regarding the classification of
these Class C explosive devices. One objective of this project is to
develop a modification to the U.N. classification scheme that the U.S.
could propose to the U.N. Group of Experts on Explosives. Additionally,
this project is to provide RSPA with an evaluation of those unique test
methods and criteria for explosives contained in Title 49, CFR to see if
they can be merged with the U.N. scheme or if some of the existing
criteria should be retained in DOT's major revision of the explosive
regulations which are scheduled for completion in 1990.
(6) Development of Test Criteria for Evaluating Detonation,
Deflagration, Mechanical Sensitivity and Explosive Power of Organic
Peroxides. Development of the test methods and criteria for assessing
41
the hazardous properties of organic peroxides and determining packaging,
temperature controls and other requirements for safe transport of
organic peroxides has been completed. Results obtained from the
previous tasks under this study enabled the U.S. to play an active role
in the development of the U.N. classification scheme for organic
peroxides which was adopted by the U.N. Committee of Experts for
Transport of Dangerous Goods in December 1986. Three new tasks were
added to this project in 1987 to further refine the Gap Test method for
assessing the detonability of organic peroxides in paste and gel forms.
This project should provide RSPA with sufficient information for
adopting the U.N. classification scheme for organic peroxides into
RSPA's HM-181 rulemaking.
(7) Highway Transportation of Radioactive Material. Work
continued throughout 1987 on projects already initiated. These projects
include:
(a) Evaluation of the radiological consequences of release of
low specific activity radioactive material (LSA) during
an accident;
(b) Study of the consequences of severe accidents involving
radioactive material in large numbers of Type A packages:
and
(c) Tabulation of the relative detection sensitivity for 2
radiation detection instruments for the types of
radioactive materials being transported.
The FHWA continued its research on "Evaluation of the Corrosion
Integrity of Cargo Tanks." A Draft Final Report has been submitted and is
under review. A Final Report is anticipated in early 1988.
The study evaluated the corrosion integrity of cargo tanks currently in
operation for the purpose of developing and recommending cost effective
procedures for monitoring and controlling cargo tank corrosion so as to
minimize corrosion-induced cargo tank structural failures.
Preliminary conclusions are that:
-
Pitting-type corrosion of stainless steel cargo tanks is the most
frequent unanticipated cargo tank corrosion problem;
-
Most preventive measures used are generally adequate, in
themselves, however, specific improvements may be made. The most
critical preventive measure--proper selection of tank type and
material for a given load--sometimes is not properly applied
because of the inadequate corrosion technology background of the
individual making the selection and/or inadequate knowledge
regarding corrosion characteristics of the load;
Carriers often haul incompletely identified waste products and
combinations of products whose corrosivity is not known and cannot
be assessed by the corrosivity of the individual products. This
can lead to the carriers' selection of the wrong cargo tank for the
load and probably caused more cargo tank corrosion than any other
42
factor;
-
There may be a need for more stringent quality control and
inspection requirements for the welding of stainless steel tanks,
both during tank construction and repair; and
-
The observed practices of those ASME-certified repair facilities
included in the study were satisfactory. Non-code repairs are
being made in sections of the country in which there are no ASME-
certified repair facilities. Most facilities use unsophisticated
techniques for inspection for corrosion damage, particularly
regarding stress corrosion cracking.
FRA's Office of Research and Development continued research on tank car
improvements, tank car damage assessment and intermodal transportation of
hazardous materials. The following research projects were completed in 1987:
-
Puncture testing of one-fifth scale, and full scale tank cars
designed for chlorine service;
-
Simulated derailment tests of various configurations of MC 307/312
cargo tanks and IM 101/102 portable tanks in Trailer-on-Flatcar and
Container-on-Flatcar service;
-
Investigation of residual stress in tank cars with attachments and
with reinforcement pads.
Research that continued in 1987 included investigation of cracks in stub
sill tank cars. This program will continue into 1988 with testing of stub
sill tank car fatigue life. Work continues on critical flaw size for tank
cars in accidents; testing of a hazardous chemical monitor; a prototype
transponder for hazardous material car identification; and on analysis of the
rail fire environment and its effect on spent nuclear fuel rail casks.
43
APPENDIX A
1987 ANNUAL REPORT TO CONGRESS ON HAZARDOUS MATERIALS TRANSPORTATION
U.S. COAST GUARD BULK ACTIVITIES
PREFACE
In addition to enforcing the Hazardous Materials Regulations in
49 CFR 171-179 as they pertain to packaged hazardous materials in the water
mode, the U.S. Coast Guard issues and enforces other regulations applicable to
the transportation of packaged and bulk hazardous materials by vessel and at
waterfront facilities. Bulk shipments, which include oil and a broad variety
of other hazardous materials, are regulated under the authority of the HMTA
and other laws, and by regulations in 46 CFR Subchapters D (Tank Vessels), I
(Cargo and Miscellaneous Vessels), N (Dangerous Cargoes), and 0 (Certain Bulk
Dangerous Cargoes). Packaged shipments are regulated under the authority of
the HMTA and the Ports and Waterways Safety Act (33 USC 1221 et seq.), and by
regulations in 49 CFR 171-179 and 33 CFR Subchapter L. Information presented
by the Coast Guard in this Appendix pertains to bulk shipments of hazardous
materials by vessel and at waterfront facilities.
Some of the information contained in this Appendix is also provided in
various sections of the main body of this report. When information is
repeated it is in order to present a comprehensive picture of the Coast
Guard's efforts in that area.
REGULATORY PROGRAMS
In addition to the regulatory projects discussed earlier in this report,
the Coast Guard had regulations under development during 1987 pertaining to
bulk shipments of hazardous materials and prevention of pollution of the
environment by hazardous materials in transportation. An estimated total of
1767 work-days were expended by the Coast Guard on hazardous materials
regulatory projects, which included the following:
Implementation of MARPOL Annex II
These rules implemented MARPOL Annex II for ships. Annex II seeks to
control operational pollution and minimize accidental pollution from a group
of cargoes termed "noxious liquid substances (NLS)," which includes polluting
chemicals shipped as liquids in bulk. Operational pollution is that resulting
from normal ship operations related to carrying cargoes, such as in the
discharge of tank washings to the sea. The vessel regulations amended
46 CFR Parts 98, 151, 153 and 172 and 33 CFR Part 151 by promulgating design
and operating requirements for United States self-propelled ships, oceangoing
non-self propelled ships and foreign ships operating in U.S. waters that carry
NLS in bulk. The regulations became effective April 6, 1987.
MARPOL Annex II Reception Facilities.
These regulations require ports and terminals to make reception facilities
available to receive residues and mixtures containing noxious liquid
substances (NLS) from ships and implement the backpressure requirements of
MARPOL 73/78. The regulations ensure that ships suffer no undue delay in
discharging this material to a reception facility. The regulations became
effective April 6, 1987.
Hazardous Substances Pollution Prevention
As part of a continuing effort to protect the safety of ports and the
environment, the Coast Guard is revising the present 011 Pollution Prevention
Regulations in 33 CFR 154-156 to broaden their applicability to include
vessels and facilities which transfer hazardous materials other than oil. A
Notice of Proposed Rulemaking will be published in March, 1988 and the final
rule in the Fall of 1988.
Incinerator Vessels
A notice of proposed rulemaking on hazardous wastes incinerator ship
design and construction was published on August 25, 1986. This rulemaking:
(1) applies the requirements in 46 CFR Part 153 for chemical tankers carrying
commercial cargoes, to incinerator ships; (2) applies requirements applicable
to large fired units such as boilers and hot water heaters to the waste
incinerators to ensure safe operation and; (3) applies additional equipment
requirements to ensure the safe transfer of wastes from cargo tanks to the
incinerators. Compliance with these requirements would be a prerequisite for
an incinerator vessel to carry and burn bulk hazardous wastes at sea.
A large number of comments were received. The Coast Guard has prepared
responses to each of them, and a final rule will be published in early 1988.
Safety Standards for Existing Self-Propelled Vessels Carrying Liquefied Gases.
This rule revises U.S. regulations for existing gas ships carrying bulk
liquefied gases in U.S. waters by adopting certain standards of the IMO
Existing Gas Ship Code that are not currently in U.S. regulations. The rule
makes U.S. regulations for existing gas ships compatible with the
internationally accepted standard. The rule improves the level of safety
associated with the transport of liquefied gases, and streamlines Coast Guard
certification procedures by reducing plan review. The NPRM was issued
March 14, 1985, in the Federal Register (50 FR 10264). The final rule is
expected to be published in 1988.
Ships' Stores.
The Coast Guard continued work on a project to completely revise the
regulations contained in 46 CFR Part 147 for the shipboard use of hazardous
materials on vessels during normal operations. This docket will incorporate
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by reference the requirements of the Consumer Product Safety Commission
thereby obviating the need for Coast Guard certification of consumer type
products. The scope of the regulations was extended to address Mobile
Offshore Drilling Units (MODUs) and outer continental shelf facilities. The
regulations also address the use of hazardous materials in industrial
systems. A NPRM was published July 23, 1987, and a final rule is expected to
be published in mid-1988.
Liquefied Natural Gas Waterfront Facilities
The Coast Guard and RSPA have agreed to a revision of the
February 7, 1978, Memorandum of Understanding (MOU) between the Coast Guard
and the Materials Transportation Bureau concerning Liquefied Natural Gas
Waterfront Facilities. Because of this revision, which increases RSPA's area
of jurisdiction on these facilities, RSPA developed a Notice of Proposed
Rulemaking (NPRM) to revise their regulations in 49 CFR 193. At the same time
the Coast Guard developed an NPRM which, in addition to the changes to
jurisdiction, adds safety regulations for LNG transfers at waterfront
facilities. The NPRMs were published on May 16, 1986. RSPA's final rule was
published on January 8, 1987, and the Coast Guard final rule will be published
in February, 1988.
EXEMPTIONS AND APPROVALS
Bulk Chemical Classification
When new chemical and petroleum products are proposed for bulk shipment by
tankship or barge, the Coast Guard reviews the chemical, physical,
flammability and health characteristics of the commodity to develop
appropriate shipping requirements. These requirements include such
specifications as hull type, venting, gauging, fire protection and any special
requirements necessary for safe shipment. Approximately 30 new products were
evaluated in 1987. An increasing number of submissions are for waste
solutions, often containing toxic chlorocarbons, heavy metals and
insecticides/pesticides. Waste solutions require careful review since
compositions tend to vary and specific health data are seldom available.
In addition to domestic classifications, the Coast Guard performs nearly
all interim evaluations for international shipping by tanker. This involves
development of tentative requirements and reference cargoes before official
requirements are developed by the IMO Subcommittee on Bulk Chemicals and
entered into the International Bulk Chemical Codes. A Coast Guard
representative chairs the IMO Working Group that develops the international
requirements for the Codes. The Coast Guard's work on interim evaluations is
well recognized by classification societies and other national maritime
administrations and is used with a minimum of technical review.
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Bulk Solid Hazardous Materials.
The Coast Guard administers regulations for the carriage of solid
hazardous materials in bulk on board vessels (46 CFR 148). These regulations
are intended to ensure that bulk solid hazardous materials are shipped and
handled in a manner which is safe and protects the environment. The most
common hazardous materials carried in bulk solid form are listed in a table of
permitted cargoes in 46 CFR 148 along with their carriage requirements.
However, unlisted hazardous cargoes may be carried after evaluation and
issuance of a special permit by the Coast Guard. During 1987, a total of 4
new special permits were issued and 16 special permits renewed for the
carriage of unlisted cargoes. An estimated 20 work-days were expended on the
effort.
Letter of Compliance Program.
Under 46 CFR Parts 153 and 154, the Coast Guard issues Letters of
Compliance (LOCs) with Subchapter 0 endorsements to foreign-flag vessels
transporting hazardous liquid chemicals and liquefied gases in bulk. Issuance
of these documents fulfills a requirement in law that foreign vessels
operating in the U.S. possess a certificate endorsed to allow carriage of
these hazardous liquids in bulk.
As in prior years, 1987 saw an increase in the number of foreign vessels
transporting chemicals and liquefied gases in the U.S. Approximately 260 full
LOC examinations and an equal number of annual examinations were conducted on
foreign chemical and liquefied gas tankships by the Coast Guard. Nearly 1300
submittals were received from industry and from Coast Guard field offices on
matters concerning vessel certification and deficiencies, regulatory
interpretations, and general inquiries.
An estimated 3 work-years were expended on this activity in 1987.
Marine Safety Information System (MSIS)
The MSIS is used extensively to carry out the Letter of Compliance
program. Subchapter 0 Endorsements are maintained in the system for all
vessels so that they can be utilized by Marine Inspection and Marine Safety
Offices in conjunction with LOC examinations of foreign-flag chemical and
liquefied gas tankers.
A "universal" Certificate of Compliance is being developed It will
replace both the LOC and the Tank Vessel Examination Letter, which is issued
to foreign-flag crude and product oil tankers which operate in U.S. waters.
The COC will be an MSIS product, able to be generated at field units
throughout the Coast Guard. The Coast Guard expended an estimated 10
work-days on this project in 1987.
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INTERNATIONAL ACTIVITIES
See the International Activities section of the main body of this Report
for a description of the International Maritime Organization (IMO).
A major facet of the Marine Environment Protection Committee's (MEPC)
efforts has been the development, improvement and implementation of the
International Convention for the Prevention of Pollution from Ships, 1973, as
modified by the Protocol of 1978 relating thereto, as ammended (MARPOL).
Three of the five MARPOL Annexes pertain to the environmental aspects of the
transportation of hazardous materials: Annex I - Regulations for the
Prevention of Pollution by Oil; Annex II - Regulations for the Control of
Pollution by Noxious Liquid Substances in Bulk; Annex III - Regulations for
the Prevention of Pollution by Harmful Substances Carried by Sea in Packaged
Forms, or in Freight Containers, Portable Tanks or Road and Rail Tank Wagons.
The Coast Guard represented the United States at the 24th and 25th
sessions of the MEPC in 1987, at which, in addition to those identified
earlier in this Report, the following papers were presented:
Paper #
Topic
24/Inf. 9
A list of MARPOL Annex I reception facilities
certified as adequate with the U.S.
24/18/9
Proposal providing comment and recommendation on
periodic and intermediate surveys of crude oil
washing systems under Annex I.
25/3/3
Major proposal regarding the discharge of clean
ballast from oil tankers operating with a waiver
under Regulation 15(5) of MARPOL Annex I.
25/Inf. 10
Updated list of MARPOL Annex I reception
facilities certified as adequate within the U.S.
25/Inf. 13
List of MARPOL Annex II reception facilities
certified as adequate within the U.S.
25/3/4
Proposal providing recommendations on
implementing pollution category changes in
carriage requirements, resulting from GESAMP
hazard profile revisions for substances listed in
MARPOL Annex II.
25/12/Add. 8
Notice on the availability of published materials
in the U.S. used to implement the provisions of
MARPOL Annex II.
n/a
Annual Enforcement Report for MARPOL.
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In addition to the presentation of the above papers, the following was
accomplished at MEPC 24:
- Committee reaffirmation that any ship not in full compliance with MARPOL
Annex II by April 6, 1987 will be in violation of MARPOL 73/78, and
Committee adoption of a resolution for ensuring uniform port state
enforcement actions for those ships not in full compliance.
- Committee agreement to not allow carriage of MARPOL Annex II category A,
B, and C noxious liquid substances in deep tanks of dry cargo ships.
- Committee agreement on the U.S. recommendations concerning periodic and
intermediate surveys of crude oil washing systems under MARPOL Annex I.
At MEPC 25:
- Unanimous adoption of amendments to MARPOL Annex I to provide for the
designation of the Gulf of Aden as a Special Area.
- Committee agreement to the U.S. proposal on the discharge of clean ballast
from oil tankers operating with an equipment waiver under Regulation 15(5)
of MARPOL Annex I.
- Committee agreement for the IMO Secretariat to solicit views of member
states on the need for possible development of and Annex VI to Marpol to
provide for the control of pollution by noxious solid substances in bulk.
The Subcommittee on Bulk Chemicals (BCH) has responsibility for
international safety and pollution prevention requirements dealing with the
bulk transport of hazardous liquids and liquefied gases. As such, the
Subcommittee has responsibility for: (1) the Code for the Construction and
Equipment of Ships Carrying Dangerous Chemicals in Bulk (Bulk Chemical Code or
BCH Code), and a revised version called the International Bulk Chemical Code
(IBC Code); (2) the Code for the Construction and Equipment of Ships Carrying
Liquefied Gases in Bulk (GC Code), and a revised version the International Gas
Carrier Code (IGC Code) and; (3) Annex II of the International Convention for
the Prevention of Pollution from Ships, 1973 (MARPOL). Once developed at IMO,
the Codes, Annex II, and related documents are implemented by incorporating
them into U.S. regulations. The various IMO documents are all in some stage
of being placed into regulations.
The most significant accomplishment of BCH in 1987 was to resolve numerous
issues relative to implementation of MARPOL Annex II. Amending Annex II was a
major U.S. initiative at IMO and fulfilled a DOT Environmental Initiative.
Coast Guard recommended amendments were proposed at IMO and within a year won
IMO support. The Annex II amendments became effective April 7, 1987. The
amendments are recognized by IMO member countries, environmental groups and
the marine chemical transportation industry as a significant improvement over
the original Annex II requirements and as an effective and practical means of
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controlling marine pollution by chemical tankers. The combination of ship and
facility capacity for waste reception will eliminate the annual discharge of
approximately 820,000 gallons of NLS per year from U.S. vessels alone in U.S.
waters.
In support of Annex II, the Subcommittee developed interpretations on the
application of Annex II to vessels engaged in ocean dumping in accordance with
the London Dumping Convention and prepared draft guidelines on the carriage of
dangerous and noxious liquids on offshore supply vessels. Carriage
requirements for many chemicals proposed for bulk shipment were also
approved. In addition, the Subcommittee developed interpretations of existing
international Codes and Conventions and continued work on revising cargo tank
venting requirements for chemical tankers carrying flammable hazardous liquid
chemicals.
The IMO Subcommittee on Fire Protection (FP) has responsibility for
international safety requirements dealing with fire protection on board
vessels, including vessels carrying hazardous materials. The Coast Guard
participated in the 32nd session of the FP Subcommittee, which met in January,
1987. During that session the Subcommittee continued to review the testing
procedures for devices to prevent the passage of flame and permissible
operational procedures for gas freeing and tank washing evolutions aboard
vessels carrying hazardous materials. The subcommittee also agreed on fire
protection requirements for ships dedicated to the carriage of irradiated
nuclear fuel in casks, and reviewed and agreed upon revisions to the
"Guidelines for the Transport and Handling of Limited Amounts of Hazardous
Materials on Offshore Support Vessels."
INSPECTION AND ENFORCEMENT
Tank Vessel Examination Program
Millions of tons of oil and crude and refined oil pass through U.S. ports
each year, on U.S. and foreign flag tank ships and barges. Each of these
vessels is examined thoroughly by the Coast Guard at least once each year, and
cargo transfer operations are monitored at least twice each year. In 1987,
200,367 transfers took place in U.S. ports, of which 6333 were monitored by
Coast Guard personnel.
Responding to and investigating reports of oil and other hazardous
materials discharges resulted in a considerable expenditure of Coast Guard
resources in 1987. Many of these investigations resulted in civil penalty
action being initiated for violations of the hazardous materials and/or
pollution prevention regulations. In 1987 the Coast Guard received 9401
reports of discharges of oil and other hazardous materials. The Coast Guard
subsequently conducted 8500 investigations. These investigations resulted in
2973 reports of violations being initiated, and expenditure of approximately
64 work-years.
A-7
TRAINING AND EDUCATION
The Coast Guard offers a two-year program of hazardous materials
postgraduate training in major universities around the country leading to a
Master of Science degree that supports the Coast Guard's various hazardous
materials related missions. Programs are available in the disciplines of
chemical engineering and industrial hygiene. Graduates of this postgraduate
program are considered specialists in the marine transportation of hazardous
materials. Their projects may include:
-
review of the physical, reactivity, combustion and toxicological
properties of chemicals proposed for shipment;
-
development of specifications for containment systems for each
chemical;
-
preparation of research and other support work for several
International Maritime Organization committees.
-
review of chemical tanker and liquefied gas containment system design
standards and regulations;
-
study of occupational safety and health guidelines for the shipboard
crew; and
-
casualty analysis of shipboard chemical fires and explosions.
Normally, four quotas a year are required to fill expected billet
vacancies with an average of six officers in school at any time. In 1987 two
officers graduated, one officer commenced school and two officers continued
with the second year of the program.
One highlight in the area of training deals with a course the Coast Guard
is developing. Gas hazards in vessel tanks present some of the greatest
threats to personnel and property in shipyards and on board underway vessels.
Explosive, toxic, or reduced oxygen atmospheres present a constant threat in
daily operations involving tank entry or hot work. Reduction of these hazards
relies heavily upon competent persons to test atmospheres and maintain
ventilation for vapor reduction. These persons must have available adequate
procedures and knowledge of test equipment in order to be effective. There
are presently no regulatory or voluntary standards for the training and
competency of these persons. In partial answer to this need the Coast Guard
has joined with OSHA, the National Fire Protection Association, and interested
industry associations such as the American Institute of Merchant Shipping and
the American Waterways Operators to support and develop a public training
course for competent persons involved in testing confined spaces on vessels.
The course curriculum establishes appropriate procedures for confined
space testing, use of appropriate testing equipment, and familiarization with
principles of protective procedures such as tank ventilation. The course was
successfully presented in New York City and Mobile, AL in 1987, and several
more presentations are scheduled for 1988.
A-8
The Coast Guard offered a variety of hazardous materials training programs
in 1987 in such courses as Hazardous Chemicals, Port Operations, Explosive
Handling Supervision, and Port Safety and Security. These training programs,
which cover other areas in addition to hazardous materials, were offered at
the Coast Guard's Reserve Training Center in Yorktown, Virginia to 823
persons. 28 instructors spent a total of 24.1 work-years teaching hazardous
materials in these seven courses; additionally, 3.8 work-years were expended
in administrative support of the courses.
In addition to these programs, On-Scene Coordinator/Regional Response Team
exercises provided simulation training to approximately 1500 people from the
Coast Guard, other federal, state and local agencies, and the general public
in Hazardous Materials Incident Response with approximately 5 work-years
expended by the trainers. In 1987, field units also expended approximately
39 work-years on in-house training.
During 1987, the Coast Guard pursued numerous hazardous materials
transportation related public education efforts. In addition to those
identified earlier in this Report, the following articles on hazardous
materials were published in the Coast Guard's Proceedings of the Marine Safety
Council:
Beware of Gassy Coal
The Coast Guard Incinerator Ship Program
The Coast Guard also provided a speaker for two seminars sponsored by the
International Maritime Organization on the requirements of MARPOL. One
seminar was conducted in Argentina and the second in China. Two Coast Guard
representatives presented papers on hazardous materials issues at the Marine
Section of the 1986 National Safety Congress. Presentations on marine mode
hazardous materials transportation issues were made at two meetings of the
American Institute of Chemical Engineers (AICHE) and at two conferences
sponsored by the Hazardous Materials Advisory Council (HMAC).
RESEARCH AND TECHNOLOGY
The Coast Guard continued a research project ("Study to Improve the Health
and Safety of the Marine Hazardous Chemical Worker") to characterize merchant
seamen's exposures to hazardous vapors and liquids aboard tank vessels. The
final product of the study will be a comprehensive occupational health and
safety program for these personnel. The program will include effective
training, environmental sampling to check vapor concentration levels and a
medical monitoring program. A trial implementation of this model health and
safety program was begun at a barge company in late 1986 and the research
study will be completed in 1988.
In 1987, the National Academy of Sciences completed a study for the Coast
Guard on the safety, operational, engineering, and cost concerns associated
with vapor recovery systems used in conjunction with the loading of
A-9
hydrocarbon liquids into marine vessels. The study recommended that the Coast
Guard develope and implement a nationally coordinated program to ensure safety
and standardization of maritime hydrocarbon emission controls. It also
recommended that elements of this program include vessel safety, waterfront
facility safety, control of emissions, and industry education. The Coast
Guard is now pursuing this recommendation.
A-10
Appendix B
The Hazardous Materials Regulations are codified in 49 CFR Parts 106-177 as
follows.
Subchapter B
-
Hazardous Materials Transportation and Pipeline Safety
Part 106
-
Rulemaking Procedures
Part 107
-
Hazardous Materials program procedures
Subchapter C
-
Hazardous Materials Regulations
Part 171
-
General information, regulations and definitions
Part 172
-
Hazardous materials tables and hazardous materials
communications regulations
Part 173
-
Shippers- general requirements for shipments and
packagings
Part 174
-
Carriage by rail
Part 175
-
Carriage by aircraft
Part 176
I
Carriage by vessel
Part 177
I
Carriage by public highway
APPENDIX B
RULEMAKING ACTIONS TAKEN IN 1987
DOCKET NUMBER AND SUBJECT
DATE
ACTION
SYNOPSIS
PUBLISHED
HM-36B
3/27/87
NPRM
Proposes several changes to the incident
Detailed Hazardous Materials
reporting form (DOT 5800.1) to provide
Incident Reports
more meaningful, comprehensive data.
HM-126C
8/20/87
NPRM
Proposes requirements for additional
Emergency Response
emergency response information on
Communication Standards
shipping papers and the placement of
response action information in all
places, including vehicles, where
hazardous materials are transported in
commerce.
B-2
9/4/87
Extension
Extended comment period from
of Comment
September 21, 1987 to December 22, 1987.
Period
HM-126D
8/10/87
Final Rule
Incorporates into the HMR definitions for
Bulk packagings and
bulk packagings and non-bulk packagings
Miscellaneous Amendments
and makes other miscellaneous changes to
the HMR.
HM-145E
3/19/87
Final Rule
Removed an obsolete hazardous substance
Reportable Quantity of
discharge reporting requirement from the
Hazardous Substances
HMR.
HM-145F
2/17/87
Final Rule;
Corrects errors in regulatory text of
Hazardous Substances;
Corrections
final rule under Docket HM-145F published
Corrections
on November 21, 1986.
7/1/87
Final Rule
Revised the definition of "hazardous
substance", to clarify that the
definition does not apply to petroleum
products that are lubricants or fuels.
10/27/87
Suspension
Suspended RQ value of certain substances
of
pending EPA's final rule. Incorporated
Effective
the proper shipping name ORM-E, n.o.s.
Date
into the Hazardous Materials Table.
HM-149E
3/2/87
NPRM
Proposes renewal for two years (statutory
Exceptions for Specified
exemptions) for specified quantities of
Quantities of Radioactive
radioactive materials.
Materials
HM-149E
5/1/87
Final Rule
Renews the exceptions for specified
Exceptions for Specified
quantities of radioactive materials in 49
Quantities of Radioactive
CFR 173.4, 173.421-1 and 173.421-2.
Materials
HM-164A
7/16/87
NPRM
Proposes to amend 49 CFR 177.825 to
State Designations of
require that, when a state routing agency
Alternative Routes for
designates an alternative route for the
Radioactive Materials
transportation of highway route
Transportation
controlled quantities of radioactive
B-3
materials, the state must give written
notice of such designation to the
Research and Special Programs
Administration.
HM-164B
7/16/87
NPRM
Proposes to amend the HMR to require
Notification to RSPA of Route
carriers, rather than shippers, give
Plans for Radioactive Materials
written notice to RSPA of route plans and
Transportation
other information relating to the
transportation of highway route
controlled quantities of radioactive
materials.
HM-166U
4/20/87
Final Rule
Incorporates into the HMR miscellaneous
Transportation of Hazardous
amendments to update the regulations,
Materials; Miscellaneous
reduce RSPA's backlog, and eliminate the
Amendments
need for DOT approvals.
HM-166V
7/6/87
NPRM
Proposes to amend the HMR, to permit the
Uranium Hexafluoride
transport of uranium hexafluoride in
packages that do not meet the
requirements of American National
Standards N14.1-1982 or DOT Class 106A
specifications for multi-unit tank car
tanks.
HM-166V
3/12/87
Emergency
Removed the requirement that all uranium
Uranium Hexafluoride
Final Rule
hexafluoride (UF₆) cylinders be cleaned
in accordance with specific procedures
contained in Appendix A of the American
National Standards Institute (ANSI)
Standard N14.1-1982.
7/6/87
Revision to
Revises previous amendments on the
Final Rule
transport of uranium hexafluoride.
HM-176A
7/10/87
Safety
Purpose of Notice is to inform all
B-4
DOT 3AL Aluminum Cylinders;
Advisory
persons that possess DOT 3AL cylinders of
Safety Problems
and ANPRM
problems associated with those cylinders
and to request comments concerning the
extent of the problem and how to resolve
it.
HM-181
5/5/87
NPRM
Proposes to amend the HMR to incorporate
Performance-oriented Packaging
features found in the United Nations
Standards; Miscellaneous
Committee of Experts Recommendations on
Proposals
the Transport of Dangerous Goods and the
Technical Instructions for the Safe
Transport of Dangerous Goods by Air
(ICAO).
11/6/87
Corrections
Provides supplements and corrections to
and Supple-
the proposals in the May 5, 1987
mental
publication of the NPRM on Performance-
Proposals
oriented Packaging Standards.
HM-189E
9/30/87
Final Rule
Corrects editorial errors and makes minor
Editorial Corrections &
regulatory changes which do not impose
Clarifications
any new requirements on persons subject
to the HMR.
HM-199
5/20/87
NPRM
Proposes to require carriers furnish
Enforcement of Motor Carrier
documentary proof, to the person offering
Financial Responsibility
the hazardous material for
Requirements
transportation, that the carrier
possesses the minimum level of financial
responsibility prescribed by 49 CFR Part
397.
HM-200
6/29/87
ANPRM
Requests comments on the need for, and
Hazardous Materials in
possible consequences of extending the
B-5
Intrastate Commerce
application of the HMR to all intrastate
transportation of hazardous materials in
commerce.
9/21/87
Extension
Extended comment period from September
of Comment
28, 1987 to November 28, 1987.
Period
HM-201
12/8/87
ANPRM
Proposes new safety standards which would
Detection and Repair of Cracks,
require railroad tank car owners and
Pits, Corrosion, Lining Flaws,
repair facilities to inspect for cracks
Thermal Protection Flaws, and
after certain tank repairs to assure that
Other Defects of Tank Car
no cracks exist.
Tanks.
HM-201B
12/8/87
NPRM
Proposes the development of safety
Thin Wall Tank Cars
standards for use of Tank Car Tanks with
localized thin spots.
APPENDIX C
400 Seventh Street SW
U.S. Department
Washington DC 20590
of Transportation
Research and
Special Programs
Administration
HAZARDOUS MATERIALS TRANSPORTATION
DOT PENALTY ACTIONS RESULTING FROM VIOLATIONS OF HAZARDOUS MATERIALS REGULATIONS
The information contained in this publication summarizes penalty actions taken by
agencies of the Department of Transportation in exercising their authority and
responsibility for the enforcement of hazardous materials regulations. The
penalty actions are grouped by the administration conducting the enforcement
action. Each case contains the name of the shipper, carrier or person(s)
involved; a description of the violations; reference to the regulations violated;
and the penalty collected. The penalties cited do not explain the mitigating or
aggravating factors that, in accordance with the statutory assessment criteria,
were considered in arriving at the final penalty and account for penalty
variations in cases that are somewhat factually similar.
Total penalties collected by mode by Fiscal Year:
FY 85
FY 86
FY 87
(FAA)
Air
$ 291,100
$ 383,250
$ 305,900
(FHWA)
Highway
437,225
366,500
292,300
(FRA)
Rail
655,050
621.575
646,750
(RSPA)
Intermodal
127,925
79,163
126,625
(USCG)
Water
104,100
23,645
83,150
$1,615,400
1,474,133
$1,454,725
The regulations referenced in each case summary are codified in the appropriate
Code of Federal Regulations (CFR) identified below:
O
CFR, Title 33, Navigation and Navigable Waters, Parts 1-199
CFR, Title 46, Shipping, Parts 1-199
CFR, Title 49, Transportation, Parts 100-199 and 300-399
International Civil Aviation Organization (ICAO) Technical Instructions
for the Safe Transport of Dangerous Goods by Air
For questions concerning these actions, contact the following persons in the
appropriate agency:
Edward Bonekemper
(202) 366-4400
FAA
Allan Horowitz
(202) 267-3137
RSPA
FHWA Paul Brennan
(202) 366-0834
FRA
Thomas Phemister
(202) 366-0635
USCG LCDR. S. V. Hughes
(202) 267-0497
OFFICE OF HAZARDOUS MATERIALS TRANSPORTATION
AUGUST 1988
FEDERAL AVIATION ADMINISTRATION
BURLINGTON NORTHERN
Offered for transportation on an improperly classed marked described labeled
$
600.00
AIR FREIGHT (Shipper)
an packaged shipment of hazardous materials. Failed to instruct employees
having responsibility for the shipment as to the applicable hazardous
materials regulations. [171.2(a). 202(a) (1), 172.300, 301(a); 173.1(b)].
Case No. 81WE750211.
COMBUSTION
Offered for transportation a shipment of paint, the contents of which were
20,000.00
ENGINEERING (Shipper)
not disclosed. Failed to mark or label shipment to indicate the contained
hazardous materials; failed to properly identify contents on shipping papers
and failed to instruct employees as to the applicable hazardous materials
regulations. [171.2(a); 172.200(a), 172.202(a) (1-4). 172.203 (c) (1) (f),
172.204(a) (c) (1) (2) (3). 172.300(a), 301(a). 312(a) (1) (2), 172.400(a);
173.3(a), 173.128(a), 173.6(b) (1) (4). 173.26(a) (1), 173.24(a) (2), (c) (1) (i);
173.1(b)]. Case No. 86EA720110.
COMBUSTION
Offered for transportation aboard aircraft a container that included leaking
$
2,500.00
ENGINEERING (Shipper)
cans of paint which was not marked or labeled to indicate its hazardous
contents. Shipping papers lacked appropriate certifications, proper
shipping name and description of commodity. Commodity was not packaged in
accordance with the hazardous materials regulations. [171.2(a);
172.200(a) (1-4), 172.204(a) (c) (1) (3). 172.300, 172.301 (a) (2). 172.400(a);
173.1(b) 173.3(a); 173.24(a) (1)]. Case No. 83SW710499.
COPENE-PETROQUIMICA
Offered for transportation aboard passenger-carrying aircraft a shipment
DO NORDESTE S.A
$ 3,000.00
described on the shipping papers as flammable liquid, poisonous, N.O.S.
(Shipper)
Solvent (C-9), but which did not bear the prope- shipping name, UN
identification number or label indicating class or division of the contents.
[ICAO Part 1, Ch. 1, Para. 1.2; Part 4, Ch. 2. Par 2.4.1,3; Part 4, Ch. 3,
Para. 3.1.2, 3.4.1; Part 7. Ch. 2]. Case No. 85S0740099.
DAMES & MOORE
Failed to properly mark label and package in DOT specification packaging, a
(Shipper)
$ 1,500.00
shipment containing sulfuric acid which was later found to be leaking.
Shipment was not properly described on shipping papers which also lacked the
required certification. [172.2(a). 172.101, 172.200(a), 172.202(a) (1-4),
172.204 (c) (3), 172.300, 172.301(a). 172.312(a) (2), 172.400(a); 173.24(a).
173.25(a), 173.1(b). 173.3(a)]. Case No. 83EA710100.
DUNKIN DONUTS
Offered for transportation, a shipment containing dry ice without the proper
$ 1,500.00
(Shipper)
shipping name or UN identification number marked on the boxes or shipping
papers. Shipping papers did not include the hazard class or total quantity
of contents. Shipper failed to make advance arrangements with carrier
inasmuch as shipment exceeded 5 lbs. per package. [171.2(a). 172.200(a),
172.202(a) (2-4). 172.204(a), (c) (1) (3), 172.300, 172.301(a), 172.316(a) (c);
173.1(b), 173.615(a) Case No. 85NE700051.
FOX PHOTO (Shipper)
Offered for transportation as "tools", a shipment of propane gas cylinders
$ 25,000.00
and cans of plastic pipe cement. Shipment was not marked to indicate its
hazardous materials content nor was it packaged in accordance with DOT
specifications. Shipping papers did not include proper shipping names or
required certifications. [171.2(a); 172.200(a), 172.202,
172.202(a) (1) (3) (4), 172.203(f); 174.204(a) (c) (3); 172.300, 172.301
172.400(a), 172.402(b); 173.3(a), 173.132(a) (2). 173.24(a) (1),
173.25(a) (3)]. Case No. 85CE730107.
GLIDDEN COMPANY
Failed to properly marked and label as to its hazardous contents, the over-
$ 44,000.00
(Shipper)
pack of < shipment of phosphoric acid that subsequently leaked causing
damage to the aircraft. Shipping papers lacked the required proper shipping
name, UN identification number, hazard class and certification "Cargo
Aircraft Only." Shipper failed to instruct employees handling shipment in
the requirements of the HMR. [172.202( (1) (2) (3), 172.203(f), 172.204(a)
(c) (1) (3), 172.300, 172.301(a). 172.400(a) (b); 173.1(b). 173.6(b) (1),
173.24(a) (1) (2), 173.25(a)]. Case No. 83GL740106.
GLOBAL INTERNATIONAL
Transported a shipment of Diethyl ether classified as a dangerous good under
$ 10,000.00
AIRWAYS (Carrier)
ICAO Technical Instructions that was improperly marked and labeled and
lacked the required certifications "Cargo Aircraft Only." [171.11(a);
175.30(a) (3) (4)]. Case No. 84S0740034.
C-1
GUYANA AIRWAYS
Knowingly transported 8 container of ammunition and explosives, removed from
$ 35,000.00
(Carrier)
the baggage of a passenger, aboard passenger-carrying aircraft without
fulfilling any of the requirements for the shipment of hazardous materials
and in violation of the regulations concerning carriage aboard aircraft.
[171.2(a) (b); 175.3, 175.20, 175.30(a) (1-3), 175.33, 175.35(a).
175.75(a) (1)]. Case No. 84S0740115.
Offered for shipment aboard passenger-carrying aircraft, seven crates of
$ 1,000.00
MR. ALEX HAJDU
(Shipper)
assorted hazardous materials that were improperly packaged, identified
labeled and marked, lacked shipping papers. Some items were expressly
forbidden aboard aircraft. [171.2(a). 172.200(a). 172.202( (1-4),
172.203 (f), 172.204(a) (c) (3), 172.300. 172.301 172.400(a), 172.402(b);
173.1(b)]. Case No. 82NM720032.
HALLIBURTON SERVICES
Offered for transportation a shipment of hydrochloric acid in plastic
$ 6,500.00
(Shipper)
containers that were improperly described on shipping papers and lacked the
certification that the shipment was within the limitations prescribed for
passenger/cargo-only aircraft. Shipment was not legibly marked to indicate
upward position of the inside packaging; was improperly packaged so that
contents leaked. [171. 172.200(a); 172.202(a) (1-4), 172.204(a) (c) (3). (-
d), 172.300.172.312(a) (2),172.400(a); 173;6(b) (1); 173.263( (a) (1),
173.6(b) (4). 173.24(a) (1)]. Case No. 82SW7102361.
Offered for shipment aboard passenger carrying aircraft a crate containing a
$
1,000.00
HYUNDAI CONSTRUCTION
(Shipper)
radionuclide that was not intended for use in or incident to research or
medical diagnosis and was not excepted under the regulations, outer
container lacked the required radioactive label and "Cargo Aircraft only
notations. [172.200(a). 172.202(a) (1-3), 172.203(d) (f), 172.204(a) (c) (3),
172.300, 172.400(a). 172.402(b). 172.403(1 (f), 172.393(p). 173.1(b)]. Case
No. 82NE710012.
JET EAST INC.
Offered an improperly packaged labeled and described shipment of resin
$ 5,000.00
(Shipper)
solution and methyl ethyl ketone peroxide for transportation aboard
passenger carrying aircraft which leaked causing illness to baggage
handlers. Both substances were either forbidden or in excess of the amounts
permitted aboard passenger arrying aircraft. [171.2(a). 172.200(a),
172.202 (a) (1-4), 172.203(2). 172.204(a) (c) (1) (3), 172.300, 172.301(a),
172.312 (a) (2), 172.400(a). 172.402(b); 173.1(b). 173.6(b) (1) (3) (4),
173.21(a 173.24(a) (1) (2), 173.27 172.101 (d) (1) (h) (1); 173.27(a)].
Case No. 84S0730161.
Failed to notify pilot of the presence and location of a cargo of cement
$ 2,000.00
MARKAIR INC.
(Carrier)
mixers with internal combustion engines. classified as hazardous materials.
[175.33; 172.203; 175.30(b)]. Case No. 84AL720042.
Offered for transportation shipment of aerosol cans without the proper
$ 2,500.00
MICHAELJOHN (Shipper)
shipping papers, labels, and packaging identifying the product as compressed
gas, a hazardous material. [171.2(a). 172.200(a), 172.202 (1) (4).
172.204, (a), (c) (1) (3); 172.300, 172.301(a). 172.400(a); 173.1(b); 173.3(a),
173.305 (c) (1)]. Case No. 82WP710606.
OXOID CANADA
Improperly described a shipment of sodium borohydride, a substance forbidden
$ 9,000.00
(Shipper)
aboard passenger-carrying aircraft, as biological materials. Failed to mark
and label the shipment to indicate its dangerous content or to package in
accordance with the regulations. Shipment was transported aboard passenger-
carrying aircraft and broke open during flight. [ICAO Part 1, Ch. 1, Para.
1.2: Part 4. Cb. 1, Para 1.1(f). Ch. 4, Para. 4.1.2, 4.1.3(a) (d) (e) (g),
4.1.7, Para. 4.3.1(a) (b). Ch. 2, Para. 2.4.1. 2.4.3, Ch. 3, Para. 3.1.1,
3.2.8(b); Part 3, Cha. 1, Para. 1.1.2]. Case No. 85S0 740013.
Offered for transportation a shipment of hazardous materials that were
$ 33,000.00
PORTEC. PATHFINDER
DIV (Shipper)
improperly described on airbills and bore no indication of the hazardous
nature of the contents. Shipping papers lacked the proper shipping name and
required certifications. Shipment was packaged in non-specification
packaging, improperly labeled and marked. [171.2(a), 172.200, 172.202 (1-
4), 172.203 172.204(a) (c) (3), 172.300, 172.312(a) (2), 172.400,
172.402(b); 173.1(b). 173.3(a). 173.24(a) (1)]. Case No. 86WP710021.
REPUBLIC AIRLINES
Transported shipments of various hazardous materials with incomplete or
$ 17,000.00
(Shipper)
improper shipping papers. Failed to provide pilot with proper documentation
and failed to establish training programs with ICAO Technical Instructions
for its employees. (ICAO Part, Ch. 1, Para. 1.2; Part 5 Sec. 4, Para.
4.1.1(b) (f); Part 6, Section 1, Para. 1.1(d)]. Case No. 83CE730068.
C-2
SIEMANS CORPORATE
Over packed three properly packaged and described cartons containing
RESEARCH AND SUPPORT
$ 35,000.00
hazardous materials without affixing to the outer container, the appropriate
(Shipper)
labels, marking and certifications that would indicate the hazardous nature
of the contents. Consequently, shipment was transported aboard passenger
carrying aircraft when the commodity was either forbidden or exceeded the
quantity permitted. [171.2(a); 172.200(a), 172.202(a) (1-4), 172.203
172.204(c) (3), 172.300, 172.301(a), 172.400(a). 172.402(b); 173.6(b) (2),
173.24(a) (1). 173.25(a) (3) (b). 173.1(b)]. Case No. 85GL740050.
SOFUKU TRADING CO.
Shipped a package containing 1 kilogram of Dioxane, classified as a
(Shipper)
$ 3,000.00
flammable liquid to the U.S. without properly executed shipping papers
describing the contents by its proper shipping name and without any markings
on the container to indicate the hazardous nature of the contents. Failed
to instruct its employees in the requirements of the Hazardous Materials
Regulations. [171.2(a), 172.200(a), 172.202(a) (1-4), 172.204(a),
172.204(c) (3), 172.300. 172.301 172.312(a) (2), 172.400(a); 173.1(b)].
Case No. 85GL740030.
DAVID S. SULLIVAN
Misrepresented a package offered for transportation and later found to
(Shipper)
$ 1,000.00
contain gasoline and strike/anywhere matches, but which as not containing
hazardous materials. Presented no shipping papers describing the hazardous
materials. Strike/anywhere matches are prohibited aboard passenger carrying
and cargo only aircraft. [171.2(a); 172.200(a), 172.203(f). 172.204,
172.300, 172.312(a) (2), 172.402(b)]. Case No. 81AL720069.
SUMITOMO CORP. OF
AMERICA
Offered for transportation a shipment of Sumithion L-50 without the proper
30,000.00
description, shipping name and identification number affixed to the
(Shipper)
packaging or the shipping papers and in non-specification packaging.
Contents leaked causing illness to the crew unloading the shipment.
[172.2(a). 172.200(a), 172.202(a) (1-4), 172.204(a) (c) (3), 172.300, 172.301;
173.3(a), 173.6(b) (1), 173.24(a) (1) (2)]. Case No. 86S0740096.
SUN SUPPLY (Shipper)
Offered for transportation aboard aircraft a shipment of paint
$ 1,000.00
misrepresented as "cornstarch" and "medical supplies" on the waybill.
Waybill bore no indication that shipment contained hazardous materials. No
shipping papers accompanying the shipment and no "Cargo Aircraft Only" or
"flammable" labels were affixed to the packages. Shipper failed to instruct
employees in the requirements of the hazardous materials regulations.
[171.2(a), 172.200(a), 172.202(a) (1-4), 172.203(f). 172,204(a) (c) (1) (3) (d),
172.300, 172.301(a) 172.400(a), 172.402(b); 173.1(b)]. Case No.
82NM710038.
TEXAS AIRFREIGHT
Accepted and offered for transportation a shipment of dangerous goods
$ 1,000.00
(Shipper)
without the proper documentation including the proper shipping name and
assigned identification number. [ICAO Part 1, Ch. 1, Para. 1.2; Part 4, Ch.
4, Para. 4.1.2; Part 4, Ch. 2, Para. 2.4.1, Ch. 3, Para. 3.1.1; Part 5, Ch.
1, Para. 1.1.2]. Case No. 85SW700029.
TEXAS INTERNATIONAL,
INC. (Carrier)
Accepted, transported aboard passenger aircraft and offered for transporta-
$ 5,000.00
tion a shipment containing explosives that was improperly classified, and
identified and not packaged in accordance with DOT specifications. Shipping
papers were incorrect and incomplete and carrier failed to instruct
employees in the requirements of the hazardous materials regulations.
[171.2(a) (b); 172.200(a) (1) (2) (4); 172.204(c) (3), 172.300; 172.301(a);
173.1(b), 3(a); 175.3; 175.20; 175.30(a) (1) (2) (3); 175.33; 175.35(a)]. Case
No. 82NW720007.
UNIVERSITY OF ALASKA
Shipped 8 package of marine specimens packed in formaldehyde solution
$ 3,000.00
(Shipper)
without any markings or indication of the presence of hazardous materials.
Package was found to be emitting a strong vapor. No shipping papers
accompanied the shipment. Cartons lacked "This End Up" marking to indicate
the proper orientation of inside packaging and were not marked with the
proper shipping name and identification number of the commodity. [171.2(a);
172.200(a), 172.204(a) (c) (1-3), 172.300, 172.301(a). 172.316(a); 173.1(b),
173.3(a), 173.510(a)]. Case No. 85WP710151.
UNIVERSITY OF GEORGIA
Shipped glacial acetic acid in a DOT exemption packaging not authorized for
$ 3,000.00
(Shipper)
transportation of that commodity by air. Package was not accompanied by
shipping papers and lacked required "Corrosive" and Cargo Aircraft Only"
labels. Failed to instruct employees in the requirements of the applicable
hazardous materials regulations. [171.2(a); 172.200(a); 172.202(a) (1-4);
172.203(f) 172.204(a) (c) (1) (3). 172.300, 172.301(a), 172.312(a) (2),
172.400(a), 172.402(b); 173.3(a), 173.1(b)]. Case No. 82S0730444.
C-3
Offered for transportation aboard aircraft, a shipment of ink, a flammable
$
500.00
WHITAKER CABLE CORP.
(Shipper)
liquid. Packages were not marked with the proper shipping name, the
required U.N. number, or "Cargo Only Aircraft label. [171.2(a).
172.202(a) (3), 172.300, 172.204(b); 173.1(b)]. Case No. 81CE710059.
YAIR IMPORT AND
Offered a shipment of cigarette lighters filled with butane and equipped
$ 3,300.00
EXPORT CORP.
with an ignition element as checked baggage aboard passenger carrying
(Shipper)
aircraft. No shipping papers accompanied the shipment which bore no
markings or "flammable" labels, no proper shipping name, identification
number or hazard class. The offering for transportation of these lighters
is forbidden. [171.2(a), 172.200(a), 172.202(a) (1-3), 172.204, 172.204(a),
172.300, 172.400(a); 173.21(e). 173.1(b)]. Case No. 81WE710451.
TOTAL
$305,900.00
FEDERAL HIGHWAY ADMINISTRATION
Failing to maintain a cargo tank certificate or manufacturer's
$ 4,000.00
ADAMS OIL CO., INC.
(Carrier)
data report at the carrier's place of business. 177.814(a) - 4 counts.
AMERICAN FIREWORKS
Shipping paper did not indicate proper shipping name, hazard class and total
$
400.00
CO., INC.
quantity. Failure to maintain at principal place of business proof of
(Carrier)
required financial responsibility. 177.817(a)-1 count. 387.7-1 count.
AQU AIR CORPORATION
Offering hazardous material for transportation not properly packaged for
$ 1,000.00
(Carrier)
shipment. 171.2(a) & 173-268-2 counts.
AROMATIC TRUCKING
Transporting a shipment of hazardous materials not accompanied by a properly
$ 14,000.00
(CORPORATION)
prepared shipping paper. Requiring or permitting a driver to drive its
(Carrier)
commercial motor vehicle who had not been medically examined or certified.
Using a driver not physically certified within the preceding 24 months.
177.817(a)-13 counts. 177.804 and 391.45(a)-5 counts. 177.804 and
391.45-1 count.
ASHLAND OIL, CO.
Operating cargo tank without operable remote emergency discharge control.
$ 1,000.00
(Carrier)
173.33 and 178.342-5-1 count.
ATLANTA FUEL CO.
Operating cargo tank not equipped with remote emergency shutoff control and
$ 5,000.00
(Carrier)
metal specification plate, and emergency vents were not marked with venting
capacity. Failure to require driver to prepare driver vehicle inspection
report as required. Did not have cargo tank certificate or manufacturer's
data receipt at carrier's principal office as required. Did not have cargo
tank retest and inspection reports as required. Did not have proof of
financial responsibility at carrier's principal place of business as
required. 173.33 and 173.119-2 counts. 177.804 and 396.11(a)-1 count.
177.814(a) and 177.814(d)-1 count. 387.7(d)-1 count.
BADDOUR, INC.
Transporting a shipment of hazardous materials not accompanied by a properly
$ 6,000.00
(Carrier)
prepared shipping paper. 177.817(a)-7 counts.
Offering or accepting for transportation a hazardous material that is not
$ 6,000.00
T. H. BAYLIS CO.
(Carrier)
properly packaged. Failing to secure hazardous material on a transport
vehicle. 171.2(a)-3 counts.
BLACK THUNDER
Failure to keep systematic records of maintenance. Failure to maintain
$ 1,500.00
MARKETING, INC.
proof of required financial responsibility at principal place of business.
(Carrier)
177.804 and 396.3(b)-1 count. 387.7(d)-1 count.
CAMPBELL OIL CO.
Operating MC-306 cargo tank not in proper condition to transport hazardous
$ 4,000.00
(Carrier)
materials. Failing to mark cargo tank with date of last test or visual
inspection as required. Operating MC-306 cargo tank used to transport
hazardous materials with inoperative remote emergency discharge control
device. Operating MC-306 cargo tank used to transport hazardous materials
with inoperative heat actuated discharge control device. 173.24 and 177.801
-1 count. 177.824-1 count. 177.802, 173.33 and 178.341-5-1 count.
177.802, 173.33 and 178.341-5-1 count.
C-4
CECOS INTERNATIONAL,
Using an unauthorized cargo tank to transport hazardous materials.
$ 3,000.00
INC.
173.33(b) and 173.272(c)-1 count.
(Carrier)
CENEX
Exceeding permitted filling density of a compressed gas in a cargo
$ 10,000.00
(Carrier)
container. 173.315(a) (1)-11 counts.
CHEMICAL SALES AND
Failing to make a written report of an incident involving hazardous
$ 3,000.00
SERVICE CO., INC.
material. Offering a hazardous material for transportation without
(Carrier)
properly prepared shipping paper. 171.16-3 counts. 172.200-7 counts.
CONWAY EASTERN
Failing to give immediate notice to the Office of Motor Carrier Safety
$ 9,000.00
EXPRESS
of the occurrence of an accident involving a fatality. Transporting
(Carrier)
a shipment of hazardous materials not accompanied by a properly prepared
shipping paper. Moving a transport vehicle containing hazardous materials
that is not properly placarded. 177.804 and 394.7(a)-1 count.
177.817(a)-1 count. 177-823.(a)-1 count.
DANIS TRANSPORTATION
Transporting a package bearing a poison label in the same vehicle with
$ 6,000.00
CO., INC.
materials marked or known to be intended for consumption by humans.
(Carrier)
177.841(e)-1 count.
DOWN EAST ENERGY
Using a driver who has not completed a written examination. Failing to
$ 5,000.00
CORP.
investigate a driver's background. Using a driver who has not been medically
(Carrier)
examined and certified as physically qualified to drive a motor vehicle.
Failing to maintain a cargo tank certificate or manufacturer's data report
at a carrier's principal office. 177.804, 391.11(b) (11) and 391.35-2 counts.
177.804 and 391.23-3 counts. 177.804, 391.11(b) (6), 391.45(a)-1 count
and 177.814-4 counts.
DYTEX CHEMICAL
Failed to use authorized containers while transporting hazardous materials.
$ 800.00
CO., INC.
177.801 and 171.2(b)-1 count.
(Carrier)
EASTERN TITLE
Transporting a shipment of hazardous materials not in proper condition for
$ 6,000.00
CO., INC.
transportation. Transporting a shipment of hazardous materials not accompanied
(Carrier)
by a properly prepared shipping paper. Requiring or permitting a driver who is
has not been medically examined or certified to drive a commercial motor vehicle.
Using a driver not physically certified within the preceeding 24 months.
Failing to require driver to prepare driver vehicle inspection reports.
177.801(a)-2 counts. 177.817(a)-5 counts. 177.804 and 391.45(a)-1 count.
177.804 and 391.45(b)-3 counts. 177.804 and 396.11(a)-4 counts.
EMPIRE, INC.
Failing to maintain proof of required financial responsibility at the motor
$ 8,000.00
(Carrier)
carrier's principal place of business. Failing to maintain a driver
qualification file for each driver employed. Transporting hazardous
materials in an unauthorized cargo tank. 387.7(d)-3 counts.
177.804 and 391.51-5 counts. 177.802 and 173.33(b)-3 counts.
ENVIRONMENTAL
Offering a hazardous material for transportation with a hazardous waste
$ 3,000.00
RESPONSE, INC.
which has not been properly prepared. Failing to mark the proper shipping
(Carrier)
name and identification number on a package containing hazardous materials
offered for transportation. Failing to label a container of hazardous
material offered for transportation. Failing to provide to the motor
carrier the required placards for the hazardous materials being offered
for transportation. Loading a hazardous material into a transport vehicle
not in compliance with the loading requirements of 49 CFR Part 177.
172.205(a)-1 count. 172.301(a)- 1 count. 172.400(a)-1 count.
172.506(a)-1 count. 173.30-1 count.
EXPLOSIVES
Failing to maintain at principal place of business proof of required
$ 18,000.00
TRANSPORTS, INC.
financial responsibility. Failing to maintain required records of
(Carrier)
inspection and maintenance for motor vehicle used to transport
hazardous materials. Failing to require motor vehicle containing
C-5
class A or class B explosives to be attended. Transporting and storing a
prohibited combination of hazardous materials together. 387.7(d)-5 counts.
177.804 and 396.3-10 counts. 177.894 and 397.5-3 counts. 177.848-1 count.
FORTO CHEMICAL
Transporting a shipment of hazardous materials not accompanied by a properly $ 2,000.00
CORPORATION
prepared shipping paper. 177.817(a)-4 counts.
(Carrier)
FUEL TRANSPORT
Failure to maintain cargo tank or manufacturer's data report at principal
$ 3,900.00
SERVICES, d/b/a
place of business. False entries on record of duty status. 177.814-1 count.
CORY'S GASOLINE
177.804 and 395.8(e)-13 counts.
STATION'S, INC.
(Carrier)
GARTON OIL
Using an unqualified driver. 177.804 and 391.11(b)-3 counts.
$ 1,500.00
(Carrier)
HELLEN
Failing to make and submit to the U.S. Department of Transportation
$ 6,500.00
TRANSPORTATION
a written report of an incident involving hazardous materials. Failing
CO., INC.
to retain on file drivers' record of duty status. 171.16-9 counts.
(Carrier)
395.8 and 177.804-7 counts.
VICTOR HENRY
Failing to maintain driver qualification file for each driver. Failing to
$ 2,000.00
d/b/a
have driver transporting hazardous materials make record of duty status.
VICTORY HENRY
Failing to maintain cargo tank certificate or manufacturer's data report
OIL CO.)
at carrier's principal place of business. Failing to visually inspect cargo
(Carrier)
tank at least once every 2-year period. Operating a motor vehicle without
having in effect required minimum levels of financial responsibility.
177.804 and 391.51(a)-1 count. 177.804 and 395.8(a)-1 count.
177.814-1 count. 177.824(b)-1 count. 387.7(a)-3 counts.
E. L.
Operating motor vehicle without required minimum levels of financial
$ 5,000.00
BOLLINGSWORTH
responsibility. Failing to maintain proof of required financial responsibility
and CO.
at motor carrier's principal place of business. Using driver not medically
(Carrier)
examined and certified as physically qualified to drive motor vehicle.
Using driver not medically examined and certified every 24 months as physically
qualified to drive. 387.7(b)-1 count. 387.7(c)-1 count. 177.804 and 391.45(a)
- 1 count. 177.804 and 391.45(b)-2 counts.
JACOBS FUEL OIL
Failing to maintain complete driver qualification file for each driver used to $ 5,000.00
SERVICE, INC.
transport hazardous materials. Operating MC-306 cargo tank used to transport
(Carrier)
hazardous materials not marked with metal identification place as required.
Failing to maintain cargo tank certificate or manufacturer's data report at
carrier's principal place of business. Failing to visually inspect cargo tank
at least once in every 2-year period. 177.804 and 391.51(c)-5 counts.
173.33(b), 177.802 and 178.340(10(b)-3 counts. 177.814(a)-1 count.
173.33, 177.802 and 177.824(b)-1 count.
JONES CHEMICALS,
Failing to file a detailed hazardous materials incident report on DOT Forms
$ 2,000.00
INC.
5800.1 within 15 days. 171.16-1 count.
(Carrier)
JONES CHEMICALS,
Offering or accepting a hazardous material for transportation not properly
$ 3,000.00
INC.
packaged. 171.2(a)-1 count.
(Carrier)
KENTUCKY OIL &
Failing to maintain complete driver qualification file for driver used to
$ 6,000.00
REFINING CO.,
transport hazardous materials. Failing to require driver used to transport
INC.
hazardous materials to prepare vehicle inspection report. Failing to transport
(Carrier)
hazardous materials in authorized cargo tank. Failing to visually inspect
cargo tank at least once in every 2-year period. 177.804 and 391.51-1 count.
177.804 and 396.11(a) 1 count. 177.802 and 173.33-2 counts. 177.824-1 count.
C-6
K&K OIL CO.,INC.
Transporting shipment of hazardous material in unauthorized cargo tank.
$ 5,000.00
(Carrier)
Operating MC-306 cargo tank used to transport hazardous materials with an
inoperative heat actuated means to close the product discharge valve.
Failing to retain copy of required cargo tank 2-year visual inspection in
carrier's files. 177.802 and 173.33-1 count; 177.802, 173.33 and 178.341-5
-1 count and 177.824-3 counts.
LEE'S TRUCKING,
Operating a motor vehicle without required minimum level of financial
$ 7,500.00
INC.
responsibility. Failing to report accident. Requiring or permitting
(Carrier)
driver to make false entries on record of duty status. Failing to
maintain cargo tank certificate or manufacturer's data report at carrier's
principal office or other approved location. 387.7(a)-1 count.
177.804 and 394.9(a)-1 count. 177.804 and 395.8(a) and (e)-12 counts.
814(a)-8 counts.
LE MARS TRANSPORT
Failing to maintain driver qualification file for driver used to transport
$ 8,000.00
INC.
hazardous materials. Failing to make written report of a hazardous materials
(Carrier)
incident within 15 days. Failing to maintain cargo tank certificate or
manufacturer's data report at carrier's principal place of business.
Requiring or permitting repair of a cargo tank with a flame before it is
made gas-free. 177.804 and 391.51-3 counts. 171.16-1 count. 177.814(a)
-2 counts. 177.854(h)-1 count.
LITTLEFIELD OIL
Operating cargo tank with inadequate closures and allowing flammable liquid
12,500.00
CO.
to escape through a defect in the cargo tank shell. Operating MC-306 cargo
(Carrier)
tank used to transport hazardous materials with inoperable heat actuated
control device. Operating MC-306 cargo tank used to transport hazardous
materials without secure closures of the manhole openings (fusible vents).
Failing to maintain cargo tank certificate or manufacturer's data report at
carrier's principal office or other approved location. Requiring/permitting
driver to drive tank motor vehicle containing flammable liquid without all
valves and other closures closed and free of leaks. Operating cargo tank
motor vehicle with inoperative heat actuated control device on each product
discharge valve. Requiring/permitting driver to drive tank motor vehicle
containing flammable liquid without all manhole closures on cargo tank
closed and secured. 173.24, 173.117, 117.801 and 177.834(e) (2)-1 count.
177.802, 173.33 and 178.341-5-2 counts. 173.24, 173.29, 173.117 and
178.341-3-1 count. 177.837(e) (1)-1 count. 177.837(e) (2)-2 counts.
177.802, 173.24 173.117 and 178.341-3-1 count.
L.S. CHEMICAL
Material improperly labeled for shipment. Hazardous material in
$ 2,500.00
CORPORATION
nonspecification container. 171.2 and 172.203 (c) (2)-4 counts.
(Carrier)
173.32(c) and 178.270-14-2 counts.
JOHN W. MOCRARY,
Operating motor vehicle after having been declared out of service.
$ 1,500.00
II)
Operating motor vehicle declared out of service before repairs were made.
(Driver)
177.804 and 395.13(d)-1 count. 177.804 and 396.9 (c) (2)-1 count.
METRO LIQUID
Failing to maintain complete driver qualification files. Failing to
$ 1,200.00
CARRIERS, LTD.
require a driver to make and submit a record of duty status. Failing
(Carrier)
to maintain cargo tank certificate or manufacturer's data report at
carrier's principal office. 177.804 and 391.51-2 counts. 177.804
and 395.8-4 counts. 177.814 (a) (b)-2 counts.
FOREST E. MILLER
Operating motor vehicle without having in effect required minimum levels of
$ 9,000.00
TRUCKING, INC.
financial responsibility. Transporting shipment of hazardous materials not
(Carrier)
accompanied by a shipping paper. Failing to placard motor vehicle used to
transport hazardous materials. 387.1-1 count. 177.817-1 count. 177.823
-1 count.
MONTGOMERY OIL,
Failing to require a driver to be physically reexamined each 24 months.
$ 3,000.00
CO., INC.
Failing to maintain a driver qualification file on each driver. Failing to
(Carrier)
maintain a manufacturer's data sheet or certificate on the cargo tanks at
the carrier's principal place of business. Failing to have a cargo tank
visually inspected at least once every 2 years. 177.804 and 391.45(b)-
2 counts. 177.804 and 391.51-1 count. 177.814(a)-2 counts. 177.824(b)
-2 counts.
C-7
M & Q TRUCKING
Failing to maintain a complete driver qualification file for each driver
$ 3,000.00
CORP.
used to transport hazardous materials. Failing to report an accident
(Carrier)
involving hazardous materials. Failing to maintain a cargo tank
certificate or manufacturer's data report at the carrier's principal
office or other approved location. 177.804 and 391.51(b)-1 count.
171.16-1 count. 177.814(a)-4 counts.
NATIONAL TRANSFER
The shipping papers were not properly prepared 177.817(a)-1 count.
$ 900.00
COMPANY
(Carrier)
OAK HARBOUR
Transporting shipment of hazardous materials not accompanied by properly
$ 3,000.00
FREIGHT LINES,
prepared shipping paper. 177.817(a)-5 counts.
INC.
(Carrier)
PARADEE OIL CO
Transporting hazardous materials in unauthorized cargo tank. Failing to
$ 4,900.00
INC.)
maintain cargo tank certificate or manufacturer's data report at principal
(Carrier)
place of business. 177.802 and 173.33-2 counts. 177.814(a)-5 counts.
RADIATOR SPECIALTY
Transporting hazardous materials without properly prepared shipping papers.
$ 5,000.00
COMPANY
177.817-2 counts.
(Carrier)
REDWING CARRIERS,
Transporting hazardous materials in unauthorized cargo tank. 177.802 and
$ 6,000.00
INC.
173.33(a)-6 counts.
(Carrier)
RELIANCE CARIBBEAN
Transporting a hazardous material not accompanied by a properly prepared
$ 2,000.00
INC.
shipping paper. Operating a commercial motor vehicle without having in
(Carrier)
effect the required minimum levels of financial responsibility. 177.817(a)
-4 counts. 387.7(a)-1 count.
ROADWAY EXPRESS,
Transporting poisons with foodstuffs. 177.841(e)-
$ 3,500.00
INC.)
(Carrier)
ROMAN RESEARCH,
Transporting a shipment of hazardous materials or corrosive liquids. 177.81
$ 3,000.00
INC.)
7-2 counts. 177.848(b)-2 counts.
(Carrier)
AL SAFFER & CO.,
Operating a motor vehicle without having in effect the required minimum
$ 3,000.00
INC.)
levels of financial responsibility. Transporting a hazardous material
(Carrier)
not accompanied by a properly prepared shipping paper. 387.7(a)-
1 count. 177.817 (a)and 172.202-4 counts.
SHUCK'S OIL & GAS
Failing to enter on the shipping paper the proper description, hazard class,
$ 2,500.00
(Carrier)
and identification number of a hazardous material. 172.202(a)-2 counts.
SAVINGS OIL CO.,
Failing to maintain complete driver qualification file for each driver.
$ 5,000.00
INC.
Failing to require driver to prepare driver vehicle inspection report at
(Carrier)
completion of each day's work on each vehicle operated. Failing to maintain
cargo tank certificate or manufacturer's data report at carrier's principal
place of business. Failing to visually inspect cargo tank at least once in
every 2-year period. 177.804 and 391.51(c)-3 counts. 177.804 and
396.11(a) and (c) (2)-3 counts. 177.814(a)-4 counts. 177.824(b)-4 counts.
SASKATCHEWAN
Offering a hazardous material for transportation not properly described on
$ 6,000.00
MINING
the shipping papers. 172.200(a), 172.202(a)(1) and (2), 172.203 (d) (iii) and
DEVELOPMENT
172.204-6 counts.
CORP.
(Carrier)
C-8
SENTER
Requiring/permitting driver to drive after having been on duty more than
$ 2,500.00
TRANSPORTATION
60 hours in 7 consecutive days. Failing to require driver to prepare
CO., INC.
vehicle inspection report in writing at completion of each day's work,
(Carrier)
of the operating condition of vehicle used. 177.804 and 395.3(b)-6 counts.
177.804 and 396.11-4 counts.
SOFCO, INC.
Transporting a shipment of hazardous materials not accompanied by a
$ 4,000.00
(Carrier)
properly prepared shipping paper. Using a driver without medical examiner's
certificate. Using a driver not physically re-examined each 24 months.
177.817(a)-9 counts. 177.804 and 391.45(a)-2 counts. 177.804 and 391.45(b)
-4 counts.
TECHEM, INC.
Transporting a shipment of hazardous materials not accompanied by a
$ 5,600.00
(Carrier)
properly prepared shipping paper. Operating a commercial motor vehicle
without having in effect the required minimum levels of financial
responsibility. Failing to maintain driver qualification files on
drivers in your use and employ. 177.817(a)-3 counts. 387.7(a)-3 counts.
177.804 and 391.51-2 counts.
TEX-OIL, INC.
Transporting hazardous materials in an unauthorized cargo tank. Failing to
$ 4,500.00
(Carrier)
visually inspect a cargo tank at least once in a 2-year period. Moving a
transport vehicle containing a hazardous material without placarding the
vehicle on each end and each side. 177.802 and 177.33-2 counts. 177.824
-1 count. 172.504(a) and 177.823(a)-1 count.
TRICOM SHIPPING
The shipping papers did not properly describe the hazardous material.
$ 1,900.00
(Carrier)
172.202(a)-1 count.
THATCHER CHEMICAL
Operating an MC-307 cargo tank to transport hazardous materials without
$ 1,500.00
COMPANY
having safety relief devices (vents) in each cargo tank compartment.
(Carrier)
177.802, 177.33, and 178.342-4-1 count.
CLIFTON THORSON
Refilling a specification DOT 106A500 cylinder which was past due for
$ 300.00
(Driver)
retest. 173.31(d) (1) and 171.2(c)-4 counts.
TUFCO FLOORING
Transporting hazardous materials without properly prepared shipping
$ 3,500.00
EAST, INC.
papers. 177.817-2 counts
(Carrier)
N. YANKE
Failing to maintain driver qualification files on each driver.
$ 11,400.00
TRANSFER,
Failing to require driver to forward, within 13 days, the
LTD.
original of the record of duty status. Transporting hazardous
(Carriers)
materials not accompanied by properly prepared shipping papers.
391.51( (a) and 177.804-4 counts. 395.8(i) and 177.804
-5 counts. 177.817(a)-3 counts. Concluded 2/19/87
URANERZ
Offering a hazardous material for transportation not properly described
$ 4,000.00
EXPLORATION
on the shipping papers. 172.200(a), 172.202(a) (1) and 2, 172.203 (d)
& MINING, LTD.
(iii) ,and 172.204-4 counts.
(Carrier)
Requiring/permitting vehicle containing radioactive materials to be
$ 2,000.00
U.S. SCOLOGY,
INC.
parked within 5 ft. of travelled portion of public street. Failing to
(Carrier)
require driver to attend vehicle containing radioactive material
located on the shoulder of a public street. 177.804 and 397.7(b)-
1 count. 177.804 and 397.5(c)-1 count.
WIL-SAV OIL CO.
Failing to mark a cargo tank with month and year of the last test or
$ 1,500.00
(Carrier)
visual inspection. Operating an MC-305 cargo tank used to transport
hazardous materials without having oil valves in the liquid discharge
system closed. Operating an MC-305 cargo tank used to transport
hazardous materials with an inoperative remote emergency discharge
control valve. 177.824(h)-1 count. 177.837(e)-1 count. 177.802,
173.33 and 178.341-5-1 count.
TOTAL
$292,300.00
C-9
FEDERAL RAILROAD ADMINISTRATION
AMERICAN CYANAMID
Offered for transportation a placarded tank car containing nitric acid
$ 3,000.00
(Shipper)
without determining that the tank safety appurtenances and fittings were in
proper condition for transportation and without the car's closures being
properly secured. [173.31(b) (1) and (3)] 1 Count. Case No. ZACY 85-1.
AIRCO INDUSTRIAL
Offered for transportation a placarded car containing carbon dioxide
$ 5,000.00
GASES (Shipper)
refrigerated liquid with the safety valve retest overdue.
[173.31 (1) (c) (1) and (6)] 1 Count. Case No. ZAIR-85-1.
BALTIMORE AND OHIO RR Transported empty tank cars previously containing alcohol without an "Empty"
14,950.00
(Carrier)
placard and without properly securing each manhole cover. Failed to report
a hazardous materials incident in writing to the Department of
Transportation; entrained an empty placarded car last containing flammable
gas next to occupied caboose; improperly placarded trailer-on flat-car
containing corrosive liquid and resin solution and failed to properly inform
crew of the hazardous materials cargo; entrained tank car containing
flammable liquid next to occupied caboose with open flame device in
operation. [171.16(a); 174.9(b). 174.26(c). 174.92(a) (3) (7), 174.9(3) (7)] 9
Counts. Case No. B0-84-4.
BALTIMORE AND OHIO RR
Cut off while in motion placarded flat car containing an oxidizer and
12,400.00
(Carrier)
permitting two cars moving under their OWN momentum to strike said flat car.
[174.84(a) (b)] 2 Counts. Case No. B0-85-3.
BALTIMORE AND OHIO RR
Improperly entrained placarded cars containing various hazardous materials
38,425.00
(Carrier)
in various locations in the consist of the train. Transported placarded
tank cars last containing flammable gas, liquid caustic soda, flammable
liquid without providing crew with proper shipping papers, placard notation
or placard endorsement. Cut off in motion. Flat car carrying empty
placarded trailer and permitting flat car to be struck by another flat car.
[174.91, 174.26(c). 174.84(b). 174.92(a) (7)] 16 Counts. Case No. BO 85-17.
BALTIMORE AND OHIO RR
Improperly entrained loaded placarded tank cars containing various hazardous
$
9,025.00
(Carrier)
materials in various locations in the consist including car containing
corrosive liquid next to open top car loaded with scrap iron protruding
beyond car ends. Transported empty placarded car with unsecured manhole
cover. [174.9(b). 174.91, 174.92(a) (6)] 5 Counts. Case No. BO 85-22.
BALTIMORE AND OHIO RR
Transported leaking tank car without markings to indicate its condition.
21,450.00
(Carrier)
Entrained placarded cars as the third car from the engine and next to loaded
flat car without bulk heads. Failed to provide train crew with proper
shipping papers or correct train profile information. Failed to provide
interchange company with billing for interchange car. [174.10(c).
174.26(b) (c), 174-50(d). 174.91, 92(a) (5); 172.202, 203] 7 Counts. Case No.
B0-85-26.
BALTIMORE AND OHIO
Entrained 4 loaded tank cars containing flammable gas as the second, third,
$ 8,000.00
(Carrier)
fourth, and fifth cars from the engine. [174.91] 4 Count. Case No. B0-85-
27.
BALTIMORE AND OHIO RR Transported empty placarded tank cars last containing chlorine and denatured
11,700.00
(Carrier)
alcohol without providing train crew with copies of shipping papers.
[174.26(c)] 3 Counts. Case No. B0-85-33.
BALTIMORE AND OHIO RR
Entrained loaded tank car containing alkaline liquid next to open-top car
$ 2,850.00
(Carrier)
with lading protruding beyond car ends. [174.92(a) (6)] 1 Counts. Case No.
BOCT-84-1.
CHESAPEAKE AND OHIO
Entrained two tank cars loaded with flammable gas and flammable liquid and
42,750.00
RAILWAY CO. (Carrier)
one empty car previously containing flammable gas, as the first and third
cars behind the engine and the fifth car from the occupied caboose. Failed
to provide crew with copies of shipping papers or papers indicating position
of car containing explosives. Transported empty car without marking and
placarding and without ensuring that manhole covers were secure. Described
cleaned and purged tank car as containing hazardous material. [174.26(c).
174.59, 174.91, 93; 172.202(e)] 17 Counts. Case No. CO-84-3.
CHESAPEAKE AND OHIO
Failed to inspect cars containing oxidizer and nonflammable gas to determine
$
3,250.00
ROADWAY CO. (Carrier)
whether car was leaking or that all covers, valves and plugs were securely
fastened. Entrained car containing flammable liquid as third car from the
engine. [174.9, 174.91] 3 Counts. Case No. CO-85-3.
C-10
CHESAPEAKE AND OHIO
RAILWAY CO. (Carrier)
Failed to file a hazardous materials incident report within 15 days of the
incident. [171.16(a) 1 Count. Case No. CO-85-20.
$ 1,500.00
COLUMBIA HYDROCARBONS
Failed to properly secure closures on tank car containing carbon dioxide.
CORP. (Shipper)
[173.31 (b) (3)] 4 Counts. Case No. ZCOL-85-1.
16,000.00
CONSOLIDATED RAIL
Improperly placed loaded placarded tank car containing various hazardous
CORP. (Carrier)
25,100.00
materials on various locations in the consist. Failed to provide train crew
with copy of shipping papers or document indicating position of placarded
car in the train. Failed to properly secure manway covers in empty
placarded car. [174.9(b). 174.24(a), 174.25(a), 174.26(b) (c), 174.91,
174.92 (5) (6) (7); 172.202, 203] 10 Counts. Case No. CR-85-11.
CONSOLIDATED RAIL
Failed to provide crew with shipping papers for placarded tank cars or
CORP. (Carrier)
19,650.00
documentation indicating position of car containing hazardous materials in
the train. Incorrect information on way bill. Failed to inspect placarded
tank car received in interchange. [174.9(a), 174.25(a). 174.26(b) (c)] 7
Counts. Case No. CR-85-37.
CONSOLIDATED RAIL
CORP. (Carrier)
Transported cars containing hazardous materials lacking coupler vertical
$ 61,050.00
restraint systems. Stored car containing flammable liquid on carrier track
for 4 months. Failed to provide train crew with shipping papers or
documents indicating position in the train of cars carrying hazardous
materials. Placed cars containing corrosive material five cars from the
engine, entrained next to the engine and entrained next to car with
automatic refrigeration apparatus in operation. Failed to inspect
interchange loaded placarded cars to determine that they were not leaking
and were in proper condition for service. Failed to place cars containing
corrosive material and flammable gas near the middle of the train.
[173.31 (a) (7); 174.3, 174.8(b), 174.9(a), 174.14(a), 174.26(b) (c), 174.91,
174.92( (7)] 22 Counts. Case No. CR-85-55.
CONSOLIDATED RAIL
CORP. (Carrier)
Improperly placed cars containing various hazardous materials or previously
$ 73,750.00
containing hazardous materials in various locations in the consist. Missing
and incomplete way bills. Failed to provide train crew with documents
indicating position in train of loaded placarded cars. [174.25(a),
174.26( (c), 174.91, 174.92(a) (5) (6) (7), 174.93] 23 Counts. Case No. CR-
85-58.
CONSOLIDATED RAIL
CORP. (Carrier)
Cut off while in motion loaded cars containing flammable gas allowing one
$ 39,950.00
car to couple with another with such force as to derail and damage both
cars. Failed to instruct employees in the requirements of the hazardous
materials regulations. [174.7, 174.83 (b) (1) (2) (3)] 7 Counts. Case No.
CR-86-3.
CONSOLIDATED RAIL
CORP. (Carrier)
Cut off while in motion placarded cars containing flammable gas allowing
$ 6,000.00
cars to strike and couple under their own momentum and with more force than
necessary. [174.83(b) (2) (3)] 1 Count. Case No. CR-86-4.
ILLINOIS CENTRAL GULF
Positioned placarded cars containing corrosives next to gondola loaded with
RAILROAD (Carrier)
$ 30,750.00
steel tubing above car ends, as the second through fifth cars behind the
engine, and positioning car containing nonflammable gas next to occupied
caboose. Required placards missing or faded; crew lacking shipping papers
or documents indicating position of placarded car in the train.
[174.25(a) (b) (c), 174.26(b) (c), 174.91, 174.93] 33 Counts. Case No. ICG-84-
1.
ILLINOIS CENTRAL GULF
RAILROAD (Carrier)
Improperly prepared or missing way bills. Entrained care containing
$ 7,500.00
corrosive immediately behind the engine and next to gondola loaded above the
car ends with poles. [174.25(a) (2), 174.26(c), 174.91, 174.92(a) (6)] 4
Counts. Case No. ICG-84-2.
ILLINOIS CENTRAL GULF
(Carrier)
Transported placarded loaded tank cars without way bills and with missing
$ 3,700.00
placards. Trailer containing adhesives and paint not prepared for
transportation in accordance with the Hazardous Materials Regulations.
[174.3, 174.26(c). 174.59] 3 Counts. Case No. ICG-85-6.
MEAD CORP. (Shipper)
Offered for transportation placarded car previously containing corrosive
$ 6,200.00
liquid without manway covers being properly secured. Unloaded tank car
containing corrosive without posting caution signs. [174.67(a) (3) (k)] 4
Counts. Case No. ZMC-84-1.
C-11
MISSOURI-KANSAS-TEXAS
Transported an empty tank car previously containing a nonflammable gas
$ 2,400.00
RAILROAD COMPANY
entrained next to the caboose and without proper papers. [172.203(e
(Carrier)
174.25(c), 174.93] 2 Counts. Case No. MKT-85-6.
PVS CHEMICALS INC.
Unloaded placarded tank car containing a corrosive material without blocking
$
3,500.00
(Shipper)
wheels and without placing caution signs. [174.67( (2) (3)] 2 Counts. Case
No. ZPVS-84-1.
RAILHEAD CARTAGE
Improperly prepared shipping papers. [172.201 (2); 173.22(a)] 1 Count.
$ 2,000.00
(Freight Forwarder)
Case No. ZRC1-84-1.
SEABOARD SYSTEM RR
Improperly entrained loaded placarded cars in various positions in the
$ 41,800.00
(Carrier)
train. Train crew not in possession of shipping papers. Unsecured vacuum
relief valve on placarded tank car containing corrosive material. [174.3,
174.26(c). 174.91] 21 Counts. Case No. SBD-84-1.
SEABOARD SYSTEM
Transported cargo tank containing phosphoric acid without prior approval of
$ 3,200.00
RAILROAD (Carrier)
the Federal Railroad Administrator. [174.61(c)] 1 Count. Case No. SBD-84-3.
SEABOARD SYSTEM
Improperly entrained loaded placarded tank cars containing various hazardous
31,100.00
RAILROAD (Carrier)
materials in various positions in the train. Failed to provide train crews
with documents indicating location of each car containing hazardous
materials. Incomplete shipping papers and improperly placarded cars.
[172.504. 172,525; 174.24(a), 174.26(c), 174.59, 174.91, 174.92(a) (5) (6)] 20
Counts. Case No. SBD-84-4.
SEABOARD SYSTEM
Transported placarded tank cars containing explosives, flammable liquid,
51,400.00
RAILROAD (Carrier)
nonflammable gas and corrosives, without shipping papers or documents
indicating their position in the train in the possession of the crew.
Entrained car containing corrosives as the fourth car from the engine.
[174.26(a) (c), 174.91] 22 Counts. Case No. SBD-84-5.
SEABOARD SYSTEM
Transported cars containing various hazardous materials in various positions
12,500.00
RAILROAD (Carrier)
in the train in violation of the regulations. Shipping papers lacking
proper endorsements. [174.25(a) (2), 174.91] 27 Counts. Case No. SBD-84-6.
SOUTH POINT ETHANOL
Failed to secure all closures on car containing flammable liquid. [173.1,
$ 2,500.00
(Shipper)
173.31 (b) (3)] 1 Count. Case No. ZSPE-84-1.
STAUFFER CHEMICAL CO.
Offered for transportation in trailer on flat car DOT spec MC 312 S.S. cargo
$
2,500.00
(Shipper)
tank containing corrosive material without having received an exemption to
make such a shipment. Certified the shipment although it did not comply
with the regulations. [172.204, 174.61(c)] 2 Counts. Case No. ZSCO-84-1.
STONE CONTAINER CORP.
Offered for transportation placarded tank cars containing corrosive material
$ 6,000.00
(Shipper)
with unsecured top unloading valve, no stuffing applied to stuffing box and
manhole gasket not properly applied. [173.31(b) (3)] 3 Counts. Case No.
ZSTO-84-1.
UNION PACIFIC
Entrained empty placarded car last containing flammable solid and poison
$ 2,000.00
RAILROAD (Carrier)
next to locomotive. Failed to include "Dangerous" placard endorsement on
waybill. [174.25(a) (2), 174.93] 2 Counts. Case No. UP-85-24.
UNITED STATES STEEL
Failed to properly close all openings on cars last containing flammable
$ 5,500.00
CORP. (Shipper)
liquid, offered for transportation. [173.29(c) (1), 174.67(k)] 4 Counts.
Case No. ZUSS-85-1.
W. R. GRACE AND CO.
Failed to secure all openings in empty car, last containing corrosive
$ 500.00
(Shipper)
material, offered for transportation. [173.29(c) (1); 174.67 1 Count.
Case No. ZWRG-85-1.
WESTERN PACIFIC
Entrained cars containing flammable gas as second through fifth cars ahead
$ 12,500.00
RAILROAD COMPANY
of the caboose. Failed to provide crew with shipping papers for shipments
(Carrier)
of flammable gas. [174.26(c). 174.91] 9 Counts. Case No. WP-84-2.
WESTERN PACIFIC
Placed tank car containing flammable gas as second car from locomotive.
$ 1,400.00
(Carrier)
[174.91] 1 Count. Case No. WP-84-2.
Offered for transportation empty placarded car last containing flammable
$ 1,500.00
WHITAKER OIL CO.
(Shipper)
liquid without reapplying manhole cover after tank was unloaded. [174.67(K)
1 Count. Case No. ZWOC-84-1.
Offered for transportation empty tank car last containing flammable liquid
$ 500.00
WRIGHT CHEMICAL CO.
(Shipper)
without properly securing all car openings. [173.29(C) (1) (2)] 1 Count.
Case No. ZWCC-85-1.
TOTAL $646,750.00
C-12
RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION
ADVANCED MEDICAL
Offered special form radioactive material without IAEA Certificate of
$ 2,000.00
SYSTEMS
Competent Authority for that material prior to first export shipment; used
(Shipper)
incorrect UN numbers on shipping papers. [172.202(a) (3). 173.476(b)].
AMCHEM PRODUCTS, INC.
Offered sulfuric acid in nonspecification fiberboard boxes; offered chromic
$ 3,500.00
(Shipper)
acid in fiberboard boxes which exceeded the authorized gross weight
limitation [173.164(a) (5)]. [173.272(c)].
AUTOMATIC BRAZING
Manufactured and marked DOT 4B and 4B240ET cylinders without performing
$ 8,000.00
COMPANY
hydrostatic testing on accurate equipment; Manufactured and marked DOT
(Cylinder Manufac-
4B240ET cylinders without performing hydrostatic test on one cylinder from
turer)
each lot of 200 or less, or performing a pressure test on each cylinder at
two times service pressure; manufacturing and marking DOT 4B and 4B240ET
cylinders without properly determining the yield strength on test specimen;
manufactured DOT 4B240ET cylinders which were not properly marked on
shoulder, top head. neck, or valve protection collar. [178.50-14(a).
178.55-14(a); 178.55(14(d) (1) and (d) (2); 178.50-16(c). 178.55-16(c);
178.55-10(a)].
BERGEN BARREL & DRUM
Failed to conduct periodic cold drop testing and hydrostatic pressure
$ 9,500.00
CO.
testing for DOT 34 drums: failed to retain records of tests. [178.19-
(Plastic Drum
(a) (2) (d)].
Manufacturer)
BLANCHARD ASSOCIATES,
Altered the specification markings on an ICC 3 cylinder by placing retest
$ 2,500.00
INC.
marking (date and symbol) over specification marking; performed hydrostatic
(Cylinder Retester)
testing on inaccurate equipment; failed to record date of reinspection and
retest on inspection report. [173.34(c) (3). (e) (3) (5)].
CONTICO CONTAINER
Failed to conduct periodic cold drop testing for DOT 34 drums and DOT E-9245 $
5,000.00
(Plastic Drum And
pails [178.19-7( (2), Para. 7(c) E-9245].
Pail Manufacturer)
FEDERAL EXPRESS
Failed to ensure that all personnel operating under terms of DOT E-7060 were
$
4,000.00
CORPORATION
wearing personal dosimetry devices; failed to submit quarterly reports.
(Carrier/Exemption
[Paras. 7CH and 9C of E-7060].
Holder)
FLORIDA DRUM COMPANY,
Failed to conduct periodic drop and hydrostatic testing for DOT 5B, 6B, 17C,
13,125.00
INC.
17E, and 17H containers; failed to conduct drop testing for DOT 37A
(Steel Drum
containers. [178.82-13. 98-11, 115-12, 116-12, 118-121, 131-11(a)].
Manufacturer)
GEARHART INDUSTRIES,
Offered special form radioactive materials for export without valid
$ 1,500.00
INC.
Competent Authority Certificate; offered a Type B package without being
(Shipper)
registered with DOT as a user of the package. [173.471(d). 476(b)].
HASMAN & BAXT, INC.
Certified shipment as being in compliance when cylinders shipped were out of
$ 3,500.00
(Freight Forwarder)
test; improperly described hazardous materials on a shipping paper.
[172.202(a), 204].
MANION STEEL BARREL
Failed to conduct periodic drop and hydrostatic testing for DOT 17E drums.
$ 7,000.00
COMPANY (Steel Drum
(178.116-12(a) (1)) (2)].
Manufacturer)
ORCO WELDING SUPPLY
Failed to obtain a current retester's identification number.
$ 1,500.00
COMPANY
[17.34(e) (1) (i)].
(Cylinder Retester)
PTL - INSPECTORATE,
Failure to inspect the inside of each DOT 3AA cylinder before closing both
20,000.00
INC. (Independent
ends; failure to obtain samples from DOT 3AA cylinders for the physical and
Inspection Agency)
flattening tests; failure to verify DOT 3AA cylinders with all requirements,
including requirement that pressure gauge on hydrostatic equipment must
permit readings with an accuracy of one percent; failure to witness leakage
tests on DOT 3AA cylinders. [178.37-4(c) 14(a),17,18].
PLASTICAN, INC.
Manufactured, marked, and sold combination DOT 35/E-7803 containers without
$ 5,000.00
(Plastic Pail
conducting periodic cold drop or hydrostatic testing [178.19-7 (2) (3).
Manufacturer)
Para. 7C, E-7803].
C-13
PROSPECT INDUSTRIES
Failed to conduct periodic hydrostatic testing on DOT 17C and 17E pails;
$ 3,500.00
CORP. (Steel Pail
manufactured six-gallon DOT 17E pails with 24-gauge steel. [178.115-
Manufacturer)
12(a) (2), 116-6, 12(a) (2)].
RELIANCE-UNIVERSAL,
Failed to retest DOT 57 portable tanks as required; offered hazardous
10,000.00
INC. (Shipper)
materials in those tanks; failed to properly mark shipping name and UN
identification number on portable tanks. [172.326 (a) (1) (2).
173.32(e) (1) (ii), 128(a) (3)].
REUTER-STOKES, INC.
Offered compressed gas for transportation by air with no hazardous materials
$ 6,000.00
(Shipper)
description on the shipping papers (172.200(a)].
R. J. REYNOLDS
Offered sulfuric acid in nonspecification wooden boxes which were marked to
$ 2,000.00
TOBACCO CO. (Shipper)
indicate they met the DOT 12B fiberboard box specification [173.272].
Failed to notify foreign shipper of the requirements of 49 CFR that would
$ 2,500.00
RUGGIERI-USA,INC.
(Importer)
apply to a shipment of Class B explosives in the United States [171.12(a)].
SCOTT-GROSS, INC.
Failed to retest certain DOT cylinders at correct minimum test pressure;
$ 4,000.00
(Cylinder Retester)
conducted hydrostatic retesting with inaccurate equipment; charged and
shipped cylinders which were out of test. [173.34(e) (3), 301(c)].
SOMMERFELD WELDERS
Conducted hydrostatic retesting with inaccurate equipment; failed to enter
$ 2,000.00
SUPPLY (Cylinder
information about visual inspections. [173.34(e) (3) (5)].
Retester)
TEXAS NUCLEAR
Offered compressed gas in nonspecification container under the terms of an
$ 4,000.00
CORPORATION (Shipper)
exemption which had expired. [173.302, 306(a) (2)].
Failed to equip bottom discharge valves on MC-312 tanks with a remote valve
$ 1,500.00
WESTERN COMPANY OF
NORTH AMERICA
closure that was no less than 10 feet away, by continuing to operate under
(Shipper)
the terms of an exemption which had expired [178.343-5(b) (2) (ii)].
Failed to notify foreign shipper and U.S. forwarding agent about the
$ 5,000.00
ZAMBELLI
INTERNATIONALE
requirements of 49 CFR that would apply to a shipment of Class B explosives
(Importer)
in the United States [171.12(a)].
TOTAL
$126,625.00
UNITED STATES COAST GUARD
AAA TRUCKING CO.
Hazardous materials offered for shipment when the hazardous material was not
(Carrier)
properly described, marked or labeled. $172.202 (1) (2) and (3),
$ 500.00
172.203(i) (2), 172.204(a), 172.302(a) and 308(a)] 8 Counts. Case Number
05PS-067-86.
ALEXANDER & ALEXANDER
Improper stowage of Dilauroyl Peroxide. [172.102(1) (a)]. Case Number
(Shipper)
MV86004736/W.
$ 1,000.00
APOLLO MARINE CO.,
Various required entries missing from Dangerous Cargo Manifest; freight
LTD.
containers containing hazardous materials not placarded. [176.30,
$ 1,550.00
(Shipper)
176.76(f)] 5 Counts. Case Number MV85002356.
ATLANTIC CONTAINER
Vessel carrying packaged "Certain Dangerous Cargo" (highway route controlled
LINES
quantity of radioactive material) failed to provide COTP with 24-hour
$ 1,000.00
(Shipper)
advance notice of arrival. [33 CFR 160.211]. Case Number MV86003088.
ATLANTIC TRADING
Shipper offered a hazardous material for transportation that was not
COMPANY
properly classed. described, labeled and in condition for shipment.
$ 1,000.00
(Shipper)
[171.2(a)] 2 counts. Case Number 07-V-40096.
AUSTRALIAN NATIONAL
Vessel did not have approved combination fire nozzle for fire station in
LINE
vicinity of flammable liquid; carrier failed to remove placards from
$ 2,700.00
(Carrier)
containers with no hazardous materials; Dangerous Cargo Manifest missing
required entries. [176.30(c); 172.502(a); 176.315(b)]. Case Number
MV86000119.
Improper cargo package restraint. [176.76(a) (2)]. Case Number 07-V-60166.
$ 500.00
BADISHCHE CORP.
(Shipper)
Vessel carrier used improper shipping names on Dangerous Cargo Manifest.
$ 600.00
BELCAN N.V.
(Shipper)
[176.30(a) (3)]. Case Number MV86000143.
C-14
BELL FUELS
Improperly installed wiring and improper warning signs on a designated
$ 3,000.00
(Waterfront Facility)
waterfront facility while hazardous materials were on board. 33 CFR
[126.15(h)&(o)] Case Number 09-005/86.
BLUE STAR MANAGEMENT
Improper shipping name for a Class A Explosive on the Dangerous Cargo
$
750.00
(Shipper)
Manifest. [176.30(a) (3)]. Case Number MV86001764.
CERES CORPORATION
Waterfront facility with hazardous materials on board had electrical
$ 3,500.00
(Waterfront Facility)
equipment not maintained in safe condition; fire extinguishers not
accessible; non-approved fork lift being used; debris and rubbish piled
around and on top of spec. 51 portable tank containing hazardous materials;
smoking observed in non-smoking areas near hazardous materials; minimum
required aisles not maintained. [33 CFR 126.15] 8 Counts. Case Number
MV87001523.
CFL TRANSPORTATION,
Corrosive materials stowed on board a vessel in unauthorized location;
$ 3,500.00
INC.
Dangerous Cargo Manifest contained improper shipping names. [172.101(i);
(Carrier)
176.30(a) (3)]. Case Number MV86003582.
COLONIAL NAVIGATION
Vessel's Dangerous Cargo Manifest contained improper shipping name for Class
$
900.00
(Carrier)
C Explosives; failure to list corrosive materials and flammable liquids on
Dangerous Cargo Manifest; failure to affix master's signature on Dangerous
Cargo Manifest. [176.30] 3 Counts. Case Number MV86004733.
DELTA CHEMICALS CORP.
Hazardous materials offered for shipment when not properly described, marked
$
1,000.00
(Shipper)
and labeled (5 transport vehicles with 15 separate shipping paper
violations). [171.2(a)]. Case Number 05PS-063-86.
DIAMOND SHAMROCK
Shipper did not adequately dunnage cargo of caustic soda. [176.76(a)]. Case
$
500.00
CHEMICAL CO.
Number MV86004839/W.
(Shipper)
E. I. DuPONT de
Shipper failed to mark proper shipping names on six portable tanks.
$ 1,000.00
NEMOURS 7 CO., INC.
[172.300(a)] 6 Counts. Case Number 05PS-024-87.
(Shipper)
ELMA
Improper segregation of hazardous materials on board a vessel.
$
600.00
(Carrier)
[176.83(b) 2 Counts. Case Number MV86005248/W.
EMBIRICOS SHIPPING
No Dangerous Cargo Manifest on board a vessel carrying sulphur, a flammable
$
300.00
AGENCY, LTD.
solid. [176.30(a) (3)]. Case Number MV86001465.
(Carrier)
FEDERAL COMMERCE AND
Dangerous Cargo Manifest contained improper shipping names.
$ 1,000.00
NAVIGATION
[176.30(a)]. Case Number MV86000667.
(Shipper)
FEDERAL COMMERCE AND
Improper shipping names on Dangerous Cargo Manifest (recurring violation).
$ 10,000.00
NAVIGATION
[176.30]. Case Number MV86000146.
(Shipper)
FEDERAL PACIFIC
Required information was missing from a vessel carrier's Dangerous Cargo
$ 1,000.00
LIBERIA, LTD.
Manifest. [176.30(a) (1)]. Case Number MV86000010.
(Carrier)
FLOVAL OIL CORP.
Mobile oil transfer facility failed to display warning signs during
$ 2,000.00
(Shipper)
hazardous materials transfer. [33 CFR 126]. Case Number 07-V-10126.
HARPER ROBINSON &
Hazardous materials offered for shipment when the hazardous materials was
$ 700.00
COMPANY (Freight
not properly described. marked. of labeled (172.202(a) (3),(b).
Forwarder)
172.203 (i) (1) (i) and (ii); 172.2(a)] 4 Counts. Case Number 05PS-209-86.
JOSEPH E. SEAGRAMS &
Shipper failed to mark proper shipping names on packages; transport vehicle
$ 3,000.00
SONS
not loaded in accordance with the HMR packages did not meet the requirements
(Shipper)
of the HMR. [172.300(a); 173.30, 173.22(a) (2); 176.76(a) (2-6); 173 and 178].
Case Number 05PS-027-87.
JUGOSLAVENSKA
No Dangerous Cargo Manifest on board a vessel carrying hazardous materials.
$ 1,000.00
OCEANSKA PLOVID
[176.30(a)]. Case Number MV85002092.
(Carrier)
KIMES CORP. (Shipper)
Improper name on shipping paper. Proper shipping name not marked on
$ 800.00
packages; Labels were not on drums of flammable liquid. [172.202(a) (1),
172.301(a), 172.400(a); 171.2(a)]. Case Number 05PS-159-86.
C-15
KOREA SHIPPING CO.,
Vessel's Dangerous Cargo Manifest missing required information.
$
700.00
LTD.
[176.30(a) (c)] 2 Counts. Case Number MV86006500.
(Shipper)
675 LEASING COMPANY
Improperly prepared Dangerous Cargo Manifest. [176.30]. Case Numbe.
$
500.00
(Shipper)
MV85001507.
MAERSK CONTAINER
Failure to fulfill the requirements for designation of Designated Waterfront
SERVICE INC.
$ 3,000.00
Facility (6 Counts) [33 CFR 126.15( (h) (k) (m) (1,3,4); 126.13(a)]. Case
(Facility Operator)
Number 05PS-137-86.
MAGNESIUM ELEKTRON,
Hazardous material packaging did not meet the requirements as specified in
INC. (Shipper)
$ 1,500.00
the HMR for 8 non-exclusive use radioactive material shipment; Improper
shipping name and ID number on packages. [172.301(a), 172.2(a). 172.300,
173.425(a)]. Case Number 05PS-220-86.
NEPTUNE ORIENT LINES,
Drums of corrosive liquids were stowed under deck rather than on deck, as
$ 1,000.00
LTD.
required. [172.102]. Case Number MV86000460.
(Carrier)
NEW DAWN SHIPPING CO.
Vessel unloading Class A Explosives without required permit from Captain of
$ 1,500.00
(Carrier)
the Port; container of Class A Explosives not properly placarded. [176.100;
172.504]. Case Number MV86004295/W.
NORTH ATLANTIC LINE
Shipment of Class A and B Explosives missing labels and placards; required
$ 1,800.00
(Carrier)
information was missing from Dangerous Cargo Manifest.
[172.400(a)
5 Counts, 172.500 (2 counts); 176.30(a)]. Case Number MV86002141.
PETRASCO SERVICES,
Missing labels and placards on shipment of explosives. [172.400(a),
$
600.00
LTD.
172.500]. Case Number MV86002145.
(Shipper)
P.I.E. NATIONWIDE
Hazardous materials offered for shipment when the hazardous material was not
$
750.00
INC. (Carrier)
properly described, marked, or labeled. One transport vehicle with 5
separate shipping paper violations). [171.2(a)]. Case Number 05PS-065-86.
POWELL DUFFRYN
Designated waterfront facility handled hazardous materials with inadequate
$ 1,000.00
TERMINALS, INC.
number of fire extinguishers, uninsulated heater, fire extinguisher
(Waterfront Facility)
locations not marked, and unsatisfactory means of communications. 33 CFR
[126.15(i) (j) (k)&(o)]. Case Number 09-006-86.
PRESTON NVOCC
Hazardous material offered for shipment when the hazardous material was not
$
900.00
SERVICES (Carrier)
properly loaded, described, marked or labeled. (3 Counts) [172.202(a) (1),
172.204(d) (1); 176.76(a) (2); 171.2(a); 173.30]. Case Number 05PS-208-86.
PRESTON NVOCC
Carrier cited for 11 separate shipping paper violations in 6 transport
$ 600.00
SERVICES
vehicles. [171.2(a); 17]. Case Number 05PS-062-86.
(NVOCC)
PUERTO RICO MARINE
Incorrect proper shipping names on shipping papers; No shipper's
$ 2,600.00
MANAGEMENT
certification on shipping papers. [172.202(a) (1). 172.204(d) (1)]. Case
(Shipper)
Number 05PS-160-86.
PUERTO RICO MARINE
Information on Dangerous Cargo Manifest not taken verbatim from shipping
$ 2,600.00
MANAGEMENT
papers; no shipper's certification on shipping papers: Dangerous Cargo
(Shipper)
Manifest missing required information; freight container with flammable
liquid not placarded; prohibited smoking occurred near container with
flammable liquids. [176.24; 176.27; 176.30 (5 counts); 176.325 (2 counts)].
Case Number MV86002172.
PUERTO RICO MARINE
Vessel carrier cited for 34 separate shipping paper violations in 13
$ 4,000.00
TRANSPORT
transport vehicles. [171.2(a)]. Case Number 05PS-061-86/0SPS-160-86.
(Shipper)
REILLY TAR & CHEMICAL
Shipper failed to mark proper shipping names on portable tank; hydrostatic
$ 1,500.00
CORP.
test not conducted within last 5 years. [172.300; 173.21b (a) (1)]. Case
(Shipper)
Number 05PS-025-87.
SAGVENAY SHIPPING
Vessel carrier's Dangerous Cargo Manifest had improper shipping names and
$ 1,000.00
LTD.
missing ID numbers. [176.30(a) (3)]. Case Number MV86000416.
(Carrier)
C-16
SHED F OCEANIC
Waterfront facility handled basardous materials under circumstances not
$
500.00
STEVEDORING CO.
covered by the general permit granted in 33 CFR 126.27. [126.33]. Case
(Waterfront Facility)
Number 07-V-10645.
TOCI MARINE COMPANY
Vessel did not have shower and eyewash fountain operable at ambient
$ 1,100.00
(Carrier)
temperature (eyewash fountain frosen): vessel's hose connections not marked
with cargo piping system working pressure; cargo hose not inspected, tested
and marked. [33 CFR 153.216(a), 153.294(b). 153.940(b). 153.940(e)]. Case
Number MV86004949.
UNITED STATES LINES.
Improper shipping name and hazard class on Dangerous Cargo Manifest.
$ 1,000.00
INC.
[176.30(a)] (2 Counts). Case Number MV87000848.
(Carrier)
Improper shipping names and incorrect ID numbers on Dangerous Cargo
s 1,400.00
UNITED STATES LINES,
INC.
Manifest. (176.30(a) (3)] 14 Counts. Case Numbers MV86000681.
(Carrier)
"Mazardous materials intended for export from U.S. not properly marked and
$ 1,200.00
VELCO INTERPRISES.
LTD.
labeled in accordance with IMDG Code. [171.12(b)] 2 Counts). Case Number
(Exporter)
MV87001516.
Packages of hazardous materials incorrectly marked (2 counts): Packages of
s 2,000.00
WELLMAN DYNAMICS
CORP.
hazardous materials incorrectly labeled (2 counts): Hazardous material not
(Shipper)
loaded in accordance with the HMR. [172.300, 172.400; 173.30; 176.76(a)].
Case Number 05PS-214-86.
Mazardous materials offered for shipment when the hazardous material was not
$
3,000.00
WESTINGBOUSE ELECTRIC
CORP. (Shipper)
properly described. marked. or labeled. (2 Counts); Hazardous material not
loaded in accordance with the HMR. [171.2(a); 173.30; 176.76(a) (2)]. Case
Number 05PS-066-86.
WESTWOOD SHIPPING
Improper shipping names included on Dangerous Cargo Manifest. [176.30(a)
$ 2,000.00
LINES
(3)]. Case Number MV86002740.
(Carrier)
WHITESTONE LOGGING
Failure of waterfront facility to record dates and results of required
$ 1,000.00
INC.
hazardous materials transfer piping tests. [33 CFR 126.15(o) (7) (vii)).
(Waterfront Facility)
Case Number 17(mps)2-86.
Hot work performed OD vessel carrying hazardous materials without permission
$ 1,000.00
YAMASHITA SHIPNIHON
STEAMSHIP
of Captain of the Port. [176.54(a)]. Case Number MV86006421.
(Carrier)
TOTAL
$ 83,150.00
GRAND TOTAL $1,454,725.00
C-17
APPENDIX D
Listed below in numerical sequence, are the exemptions that were issued,
renewed or amended during the year 1987. The reason for each issuance is
given by a number in the right-hand column which is coded to the reasons
shown below:
1. to develop information and gain experience concerning innovative
forms of packagings, shipping conditions, or carrier operations;
2. to authorize packaging of similar nature and integrity equivalent
to DOT specification containers;
3. to permit one or a limited number of shipments of a material for
which an amendment of the regulations would be impractical;
4. to permit emergency movement of materials in order to prevent risk
to life or property; and
5. to permit emergency movement of a material in order to prevent
serious economic loss.
APPENDIX C
NUMBER
PURPOSE
REASON
1479
Authorizes use of non-DOT specification carso
1
tanks, for transportation of liquefied fluorine
and mixture of liquefied fluorine and liquefied
oxygen.
1862
Authorizes shipment of nitrosen in hydraulic
1
accumulators.
2000
Authorizes use of a non-DOT specification portable
2
tank or 3 DOT Seecification 4L cylinder, for
shipment of flammable liquefied compressed gases.
2462
Authorizes shipment of certain lead a azide in glass
2
bottles overpacked in non-DOT specification wooden
box.
2582
Authorizes shipment of certain hazardous materials
1
in cylinders made in compliance with DOT
Specification 3E1800, with certain exceptions.
2709
Authorizes use of DOT Specification 6J/2S or 6D/25
1
metal drum/polsethslene containers or non-DOT
specification drums, for shipment of Class A and R
explosive liquids.
2913
Authorizes use of non-DOT specification metal
2
cylinders, for transportation of certain
nonflammable and flammable nonliquefied compressed
sesus.
3004
Authorizes use of a non-DOT specification
2
cylinder, for transportation of certain flammable,
and non-flammable compressed gases.
3095
Authorizes use of 2 non-DOT specification carso
2
tank, for shipment of corrosive and flammable
liquids.
3109
Authorizes use of non-DOT specification pressure
3
vessels, for shipment of a nonflammeble,
nonliquefied compressed sas.
3121
Authorizes use of non-DOT specification carso
2
tanks, for transportation of a certain Class A
poisonous liquid.
D-2
NUMBER
PURPOSE
REASON
3128
Authorizes use of a non-DOT specification
2
cylinder, for transportation of a Class C
explosive and 8 liQuefied nonflammable 985.
3353
Authorizes shipment of certain oxidizing
2
materials, in 3 non-DOT specification steel or
aluminum portable tank.
3415
Authorizes transport of rocket motors, containing
3
certain Class A or Class R explosives, without
overpackins.
3498
Authorizes transport of open top vehicles,
1
military combat & tactical vehicles loaded w/their
combat supply of accessory ammunition UP to 6000
lbs. & not to exceed 18% of net weight of vehicle.
3569
Authorizes use of non-DOT specification
2
nonrefillable cylinders, fur transportation of a
liquid oxidizer.
3600
Authorizes shipment of Lance rocket engines in
3
specific configurations which contain Class B and
Class C explosives.
3630
Authorizes use of a DOT Specification 33A
2
polysturene case to contain four 5-pint glass
bottles of nitric acid.
3768
Authorizes use of DOT Specification MC-304, MC-307
2
and MC-312 carso tanks, for transportation of
certain flammable and corrosive liquids.
4177
Authorizes use of e non-DOT specification pressure
3
vessel containing & nonflammable, nonliquefied
985.
4242
Authorizes use of a non-DOT specification pressure
2
vessel, for transportation of certain puroforic
mixture.
4262
Authorizes shipment of charged oil well jet
2
perforating suns with initiators attached.
4291
Authorizes use of 3 non-DOT specification aluminum
2
portable tank, for transportation of a certain
oxidizer.
D-3
NUMBER
PURPOSE
REASON
4338
Authorizes use of DOT Specification 3AA2015
cylinders and DOT Specification 51 portable tanks,
2
for shipment of certain corrosive liquids and a
flammable liquid.
4354
Authorizes shipment of chloroformates, in DOT
Specification 60 or 37M cylindrical steel overpack
1
with an inside DOT Specification 2S, 2SL or 2T
polyethylene container.
4453
Authorizes use of a non-DOT specification bulk,
hopper-type tank, for transportation of blasting
2
mixtures. agent, n.o.s. or ammonium nitrate-fuel oil
4459
Authorizes manufacture, markins and sale of
non-DOT specification cylinders, for shipment of
2
flammable, nonflammable gases, Class A and B
poisons and mixtures thereof.
4661
Authorizes transport of butyl lithium in petroleum
solvent in DOT Specification 4BA240 cylinders with
2
alternative retest procedures.
4698
Authorizes use of e non-DOT specification
hydraulic accumulator, for shipment of a certain
2
nonflammable compressed $85.
4719
Authorizes shipment of certain compressed gases
not listed in 49 CFR 173.314 and 173.315, in DOT
2
Specification MC-330 and MC-331 carso tanks or
105A300W, 112A340W, 114A340, 106A500, 106A500X and
110A500W tank car tanks.
4726
Authorizes transport of certain liquid metal
fluorides, in non-DOT specification seamless monel
2
cylinders, overpacked in a strong wooden box with
cushioning material.
4734
Authorizes use of modified DOT Specification
2
MC-331 carso tanks, for transportation of certain
flammable liquids and corrosive materials.
4803
Authorizes use of a non-DOT specification carso
1
tank, for shipment of certain corrosive liquids.
D-4
NUMBER
PURPOSE
REASON
4850
Authorizes shipment of flexible linear shaped
1
charges, metal clad, in 100' lengths, containing
not more than 50 grams per linear foot of 3 high
explosive.
4884
Authorizes shipment of liquefied and nonliquefied
2
compressed sases and 2 flammable liquid in
stainless steel cylinders, complying with DOT
Specification 4RS with certain exceptions.
4932
Authorizes shipment of tear $85 devices in a
2
telescopic type, celindrical, wound-kraft
container fitted with metal ends overpacked in DOT
Specification 12B fiberboard box.
4990
Authorizes use of AAR Specification 206W tank
2
cars, for transporlaton of certain flammable
liquids.
5022
Authorizes shipment of certain Class A and Class B
1
explosives in temperature controlled equipment.
5038
Authorizes shipment of dimethyldichlorosilane:
2
trichlorosilane, other specifically identified
flammable liquids and silicon tetrachloride in
non-DOT specification type 304 stainless steel
cylinders.
5112
Authorizes use of a specially designed kettle drum
1
type aluminum containers, for transportation of a
Class A explosives
5206
Authorizes privately operated bulk hopper-type
1
units, for transportation of blasting agents.
5243
Authorizes modified DOT specification packaging
1
for transportation of Class C or Class A
explosives.
5248
Authorizes shipment of a certain Quantity of
2
polonium-210 in any DOT Specification approved
outer Type A packasins.
5403
Authorizes use of non-DOT specification cardo
1
tanks, meeting the requirements of DOT MC-312 with
certain exceptions, in support of oil well
acidizing and industrial cleaning operations.
D-5
NUMBER
PURPOSE
REASON
5557
Authorizes use of non-DOT specification
1
containers, for shipment of certain explosives,
with the gross weight exceeding prescribed limits.
5600
Authorizes transport of flammable or nonflammable
1
compressed gases, flemmable or corrosive liquids
or oxidizers presently authorized to be shipped in
a non-DOT specification cylinder made to DOT 3A
Specification except monel metal may be used
rather than steel.
5749
Authorizes use of an insulated nickel steel
2
DOT-MC-331 carso tank, for transportation of =
certain flammable gas.
5895
Authorizes use of non-DOT specification inner
1
container overpacked in e) DOT-12H fiberboard box,
or 8 wooden box for shipment class C explosives.
5923
Authorizes transport of certain flammable and
1
nonflammable gases, in DOT-106A500X and 110A500W
multi-unit tank cars.
5948
Authorizes shipment of radioactive waste materials
2
in ATMX 500 or 600 rail cars.
5951
Authorizes transport of liquefied nonflammable
2
compressed gases, in DOT Seecification 106 type
tanks.
5967
Authorizes use of a non-DOT specification
1
cylinder, for transportation of nonflammable
sases.
6016
Authorizes shipment of liquid oxygen, nitrosen,
1
and arson in non-DOT specification portable tanks.
6045
Authorizes use of DOT Seecification MC-312 cargo
1
tanks, for transportation of B flammable liquid.
6071
Authorizes use of non-DOT specification pressure
2
vessels, for transportation of nonflammable
compressed gases.
6122
Authorizes use of a full telescope half slotted
2
fiberborad box meeting the requirements of DOT
Specification 12B fiberboard box, for shipment of
certain dry organic peroxides.
D-6
NUMBER
PURPOSE
REASON
6126
Authorizes shipment or chloracetal chloride in DOT
1
Specification 6D/2S or 2SL composite packaging.
6232
Authorizes shipment of nonflammable and flammable
2
gases, and 3 flammable solid in the same outside
packages.
6267
Authorizes use of DOT and non-DOT specification
2
fiberbuard boxes, for shipment of certain
oxidizing materials.
6293
Authorizes shipment of specific corrosive
2
materials, in DOT Specification MC-311 or MC-312
tank motor vehicles.
6296
Authorizes additional bag packagings, for
2
transportation of certain Class R poisons in DOT
Seecification 44D multi-wall raper bags.
6325
Authorizes transport of oxidizers, in non-DOT
2
specification 08180 tanks or DOT Specification
MC-306, NC-307, or MC-312 carsu tanks.
6349
Authorizes use of non-DOT specification portable
1
tanks, for shipment of certain flammable and
nonflammeble gases.
6418
Authorizes use of DOT Specification MC-303,
1
MC-304, MC-306, MC-307, MC-310, or MC-312 steel
carso tanks, for transportation of Class B
poisonous liquids.
6434
Authorizes use of non-DOT specification paper
2
bags, for trensportation of 3 poisonous R solid
material.
6443
Authorizes use of DOT Specification MC-331
1
insulated carso tanks not presently authorized,
for tranportation of a flammable 925.
6452
Authorizes shipment of certain organic peroxides
2
in one sound bags, overpacked in B DOT
Specification 12865 fiberboard box.
6472
Authorizes use of non-DOT specification
2
polystyrene containers, for transportation of
certain Class Б explosives.
D-7
NUMBER
PURPOSE
REASON
6501
Authorizes transport of liQuid high explosives in
2
DOT Specification 6D steel drums overpacked with a
DOT Seecification 2SL liner.
6530
Authorizes shipment of hydrogen and mixtures of
2
hydrogen with helium, arson or nitrosen in DOT
Specification 3A, 3AA, 3AX 01' 3AAX steel
cylinders.
6531
Authorizes use of a non-DOT specification pressure
2
vessel for shipment of = nonflammable compressed
gas.
6543
Authorizes shipment of certain corrosives and
2
flammaile liquids in non-DOT specification 16
Sause, Type 304 stainless steel cylinders and/or
14 Sause Type 316 stainless steel cylinders.
6557
Authorizes deviation from the requirements of the
1
inspector's report for NOT Specification 3A, 30A,
and 4B cylinders, for shipment of certain
nonflammable compressed gases.
6583
Authorizes shipment of a corrosive material in 3
1
DOT Specification 51 portable tank.
6614
Authorizes use of non-DOT seecification
1
polyethylene bottles, packed inside a hish density
polyethylene box, for transportation of certain
corrusive liquids.
6626
Authorizes use of DOT Specification 3A or 3AA
1
cylinders and cylinders marked ICC-3, 3A or 3AA,
for shipment of certain compressed sases.
6657
Authorizes use of DOT Specification 3A or 3AA
1
cylinders having an age over 35 years for
transportation of certain non-liquefied compressed
gases.
6658
Authorizes use of a non-DOT specification
4
open-head steel drum, for transportation of a
certain Class A explosive.
6672
Authorizes menufacture, marking and sale of welded
2
or seamless, nonrefillable non-DOT specification
steel cylinders, for transportation of certain
nonliquefied compressed gases.
D-8
NUMBER
PURPOSE
REASON
6686
Authorizes use of a modified DOT Specification 39
1
steel cylinder, for transportation of a certain
flammable 985.
6691
Authorizes use of DOT Seecification 3A or 3AA
1
cylinders over 35 years old which can be retested
every 10 years, for transportation of certain
flammable and nonflammeble $3525.
6712
Authorizes shipment of certain flammable and
2
nonflammable gases in DOT Specification 3A or 3AA
cylinders or ICC-3, 3A or 3AA cylinders.
6752
Authorizes use of DOT Specification 3A, 3AAX and
1
3T cylinders forming part of 3 tube trailer or
tuise bank, for transportation of a liquefied
flammable compressed $85.
6759
Authorizes transport of Class A or B explosives in
1
an IMF 22 container or compartment on the same
vehicle with non-mass detonating blasting caps.
6762
Authorizes transport of chemical kits in plastic
1
inside bottles, packed in plastic boxes overpacked
in fiberboard boxes.
6765
Authorizes use of non-DOT specification portable
1
tanks, for transportation of = flammable and 2
nonflammable $25.
6769
Authorizes transport of trifluoromethane in DOT
2
Specification tank cars and carso tanks.
6773
Authorizes shipment of a flammable compressed 985,
1
in a DOT Seecification 105A600W tank car,
6774
Authorizes use of non-DOT specification cylinders
2
complying with DOT Seecification 3HT, with certain
exceetions, for shipment of a nonflammable 985.
6800
Authorizes manufacture, markins and sale of
2
non-DOT specification 50- and 55-gallon
solyethylene containers similar to DOT
Specification 34, for shipment of certain
flammable liquids, corrosive materials, poison E
liquids and hydrogen peroxide classed as an
oxidizer.
D-9'
NUMBER
PURPOSE
REASON
6816
Authorizes shipment of completely assembled liquid
1
and solid fueled missiles in packaging prescribed
in 173.57(s).
6824
Authorizes packagings not provided for in the
2
Hazardous Materials Regulations, for shipment of
certain oxidizing materials.
6861
Authorizes use of DOT Specification 21P fiber
2
drums with DOT Specification 2SL or 2U
polsethylene liners, for transportation of certain
Class A explosives.
6874
Authorizes transport of sodium and potassium
1
cyenides in non-DOT seecification wooden boxes.
6902
Authorizes shipment of a liquefied nonflammable
1
compressed 9851 in B modified DOT Specification
110A800W multi-unit tank car tank.
6922
Authorizes use of a DOT Specification 106A500-X
1
multi-unit tank car tank, for shipment of certain
compressed gases.
6961
Authorizes shipment of certain flammable solids in
2
a DOT Seecification 37A 20-sauge steel drum.
6971
Authorizes transport of small quantities of
1
reasent chemicals in inside glass bottles packed
in metal boxes, overpacked in a strong wooden or
fiberboard box.
6974
Authorizes use of non-DOT specification cylinders,
2
for transportation of certain nonliquefied
compressed gases.
7007
Authorizes shipment of chlorine in non-DOT
1
seecification multi-unit tank car tanks patterned
after DOT Seecification 110A500W.
7023
Authorizes use of non-DOT specification steel
2
portable tanks, for shipment of an oxidizer or
corrosive material.
7026
Authorizes manufacture, marking and sale of a
2
non-DOT specification welded steel pressure
vessel, for transportation of a compressed 985.
D-10
NUMBER
PURPOSE
REASON
7035
Authorizes manufacture, marking and sale of
1
non-DOT specification reusable, molded
polsethylene containers, for transportation of
corrosive liquids and solids, oxidizers, flammable
liquids, and Class B poisonous liquids.
7046
Authorizes use of modified DOT Specification
2
MC-312 glass lined carso tanks, for transportation
of certain corrosive liquids and a certain
oxidizer.
7051
Authorizes use of non-DOT specification Teflon
1
bottles overpacked with either = DOT Specification
12A or 12B fiberboard box, for transportation of a
corrusive liquid.
7052
Authorizes shipment of batteries containing
1
lithium and other materials, classed as flammable
solids.
7056
Authorizes one-time reuse of DOT Specification 37A
1
steel drums, for trensportation of a certain
flammable solid.
7060
Authorizes carriage of radioactive materials
1
aboard carso aircraft only when the combined
transfort index exceeds 50.0 and/or the separation
criteria cannot be met.
7063
Authorizes use of a removable-head non-DOT
1
specification polyethylene pail, for
transportation of corrosive materials.
7071
Authorizes polyethylene packagings in 3 Quantity
1
not provided for in the resulations, for
transporation of a certain corrosive liquid.
7072
Authorizes manufacture, marking and sale of
1
non-DOT specification 34 type containers for
transfortation of certain liquid organic
peroxides, oxidizers and corrosive materials,
flammable liquids and poison H liquids,
7073
Authorizes use of non-DOT specification portable
2
tanks for trausportation of a Class F poisonous
liquid.
D-11
NUMBER
PURPOSE
REASON
7087
Authorizes shipment of small Quantities of certain
2
hazardous materials in non-DOT specification
glass, polgethylene, or other plastic containers.
7205
Authorizes certain stowage deviations in the
1
transportation of military explosives by vessel.
7235
Authorizes manufacture, marking and sale of
2
non-DOT specification fiber reinforced plastic
hoop wrapped cylinders, for transportation of
certain nonflammeble compressed gases.
7252
Authorizes transport of Pourvex and Tovex Extra in
2
DOT Specification 17H metal drums.
7269
Authorizes use of sift-proof paper or plastic bass
2
overpacked in DOT Specification 21C fiber drums,
for transportation of certain Class n explosives.
7274
Authorizes use of non-DOT specification portable
1
tanks, for shipment of certain nonflammable gases.
7280
Authorizes fuel tanks to be 3/4 full instead of
1
1/4 full and vehicles to be transported with
battery cables connected if the holds or
compartments of a vessel in which vehicles are
loaded are mechanically ventilated.
7282
Authorizes use of non-DOT specification steel
2
portable tanks, for shipment of certain mixtures
of nonpoisunous: nonflammable compressed gases.
7286
Authorizes shipment of certain nonliquefied
2
compressed gases in DOT Specification 3A or 3AA
cylinders and cylinders marked ICC-3, 3A or 3AA.
7413
Authorizes transport of carbon dioxide or
2
nitrogen, in B non-DOT specification brazed steel
cylinder.
7440
Authorizes transport of a nonflammable 585, in
2
non-DOT specification one-piece, impact-extruded,
cylindrical, aluminum container.
7451
Authorizes use of non-DOT specification pressure
1
vessels, for transportation of a nonflammble $85.
D-12
NUMBER
PURPOSE
REASON
7454
Authorizes blasting agent to be stowed in
1
proximity to certain explosives without a bulkhead
separating these materials.
7455
Authorizes handling and stowage of explosive
3
material in an anchored and unmanned barge.
7458
Authorizes manufacture, markins and sale of
2
non-DOT specification seamless cylinders, for
transportation of nonflammable sases.
7476
Authorizes manufacture, markins and sale of
2
certain non-DOT specification carso tanks, for
transportation of certain flammable and corrosive
liquids and poison waste materials.
7489
Authorizes shipment of 2 corrosive liquid in
1
specified non-DOT specification metal container
having a capacity of 1 Quart or less, in a DOT
Specification 37A metal drum.
7495
Authorizes manufacture, marking and sale of
1
non-DOT seucification portable steel tanks, for
transportation of chlorine or sulfur dioxide.
7505
Authorizes use of DOT Seecification 17C drums
2
previously used for shipment of Class B poisons
and reconditioned (decontaminated).
7526
Authorizes shipment of a pyrophoric liquid in
2
non-DOT specification portable tanks.
7536
Authorizes an increase to the maximum allowable
1
draft weights for five and ten ton rated booms for
shirment of military explosives.
7542
Authorizes manufacture, markins and sale of
2
non-DOT specification steel cylinders, for
transportation of certain flammable gases.
7544
Authorizes transport of solutions of sodium
2
hydroxide and certain other liquid corrosives, or
other liquid corrosive materials in a DOT
Specification 2U polyethylene inside container,
overpacked in a non-DOT specification fiberboard
box.
D-13
NUMBER
PURPOSE
REASON
7546
Authorizes use of a heat pipe radiator assembly
3
for shipment of certain flammable liquids and
nonflammable and flammable compressed 985es.
7549
Authorizes use of a non-DOT specification 316L
1
stainless steel portable tank, for shipment of 2
certain corrosive material.
7555
Authorizes use of B carso tank made from
1
non-metallic materials for transpurtation of
certain corrosive materials.
7594
Authorizes transport of certain poison B liquids
2
in DOT Specification MC-312 carso tanks.
7595
Authorizes transport of certain poison B liquids
1
in DOT Seecification MC-312 carso tanks.
7601
Authorizes shipment of desensitized nitroglycerin
3
in non-DOT specification inside containers.
7605
Authorizes transport of certain explosives
1
contained in a partially dis-assembled aircraft or
свпору assembly.
7607
Authorizes shipment of hydrogen in certain non-DOT
1
specification seamless stainless steel cylinders.
7616
Authorizes carrier to certify the shipping paper
1
on behalf of the shipper when transforting
hazardous materials by rail.
7625
Authorizes transport of certain corrosive liquids,
2
in DOT Specification 56 portable tanks.
7628
Authorizes use of DOT Specification 111A100W-5
5
tank cars eQUIPPED with a safety relief valve
instead of 3 vent for shipment of certain
corrosive liquids.
7638
Authorizes manufacture, marking and sale of DOT
4
Seecification 4L cylinders, for transportation of
certain nonflammable compressed gases.
7641
Authorizes curriese of motor vehicles abuard carso
5
vessels with battery cables connected.
D-14
NUMBER
PURPOSE
REASON
7648
Authorizes carriase of aerial illuminating flares
3
for testing purposes in carso aircraft only.
7657
Authorizes manufacture, marking and sale of
2
non-DOT specification cylinders, for
transportation of certain compressed gases.
7694
Authorizes use of non-DOT specification welded, or
2
seamless, nonrefillable cylinders containing
non-liquefied compressed gases.
7716
Authorizes transport of ammonium nitrate in inside
2
polycthylene bottles or foil pouches, each
containing less than 3 pounds or less, overpacked
in DOT Specification 12H-65 fiberbuard boxes with
= plastic liner bas containing not more than 36
pounds net weight.
7721
Authorizes manufacture, marking, and sale of
1
non-DOT specification steel cylinders, for
transportaion of certain nonflammable,
nonliquefied compressed gases.
7730
Authorizes use of a DOT Seecification MC-312 cargo
3
tank, for transportation of certain corrosive
materials.
7731
Authorizes manufacture, marking, and Lale of
2
non-DOT specification super-insulated portable
tanks for shipment of pressurized liquid helium.
7735
Authorizes manufacture, markins and sale of DOT
1
specification 34 containers, for shipment of
certain flammable liquids and corrosive materials.
7753
Authorizes shipment of yellow phosphorous in a
2
tight-head 55 sallon DOT Seecification 17C drum.
7765
Authorizes use of nonrefillable, non-DOT
2
specification cylinders, for transportation of a
nonflammable 985.
7767
Authorizes manufacture, markins and sale of
1
non-DOT specification welded steel cylinders, for
transportation of nonflammable compressed gases.
D-15
NUMBER
PURPOSE
REASON
7769
Authorizes manufacture, markins and sale of
1
non-DOT specification fiber reinforced plastic
full composite cylinder, for transportation of
certain nonflammable compressed 335.
7770
Authorizes transport of anhydrous hydrogen
2
fluoride or anhydrous methylchloromethyl ether in
certain non-DOT specification portable tanks.
7774
Authorizes shipment of bromine trifluoride in
2
non-DOT specification cylinders.
7808
Authorizes shipment of insecticides in DOT
1
Seecification 39 cylinders equipped with a
pressure relief device.
7822
Authorizes shipment of liquid helium in
2
specifically insulated non-DOT specification
portable tanks.
7834
Authorizes transport of nonliquefied sulfur
1
hexafluoride in certain X-ray machines, overpacked
in strons wooden or fiberboard boxes.
7835
Authorizes transport of compressed 985 cylinders
1
bearing the flammable 525 label, the oxidizer
label, or the poison gas label and tank car tanks
bearing the poison gas label on the same vehicle.
7857
Authorizes use of certain non-DOT specification
2
portable tanks for shipment of certain flammable
gases.
7862
Authorizes use of non-DOT seecification aluminum,
2
single trip, inside container, for transportation
of 8 nonflammable 985.
7876
Authorizes use of a shipping descristion, etching
2
acid, liquid, n.o.s., to be used for products
which do not comply with the definition in 49 CFR
173.299(a).
7879
Authorizes shipment of bromine trifluoride, in
2
non-DOT specification seamless cylinders.
7886
Authorizes shiement of a corrosive liquid, in
2
non-DOT specification metal can/fiberboard box
packaging.
D-16
NUMBER
PURPOSE
REASON
7887
Authorizes shipment of packages of toy propellant
1
devices as an ORM-D material and excepted from
labeling requirements.
7891
Authorizes transport of packages bearing the
1
DANGEROUS WHEN WET label, in motor vehicles which
are not placarded FLAMMABLE SOLID W.
7907
Authorizes shipment of wet nitrocellulose, a
2
flammable liquid or flammable solid, in non-DOT
specification fiberboard drums.
7915
Authorizes transport of certain propellant
1
explosives in water in DOT Specification MC 307 or
MC 312 cargo tanks.
7943
Authorizes shipment of corrosive liquids in
fiberboard boxes complying with DOT Specification
2
12B except for handholes in tos flaps.
7946
Authorizes transport of various nonflammable gases
2
in non-DOT specification steel or aluminum
pressure vessels contained in 2 radiation
detector.
7948
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks for shipment of
flammable and corrosive waste materials.
7963
Authorizes transport of perchloromethyl mercaptan
2
and thiophene-2-acetyl chloride, in mone] tanks
constructed in accordance with DOT Ssecification
51.
7972
Authorizes transport of limited Quantities of
1
explosives in a special shipping container without
placarding the vehicle.
7991
Authorizes transport of railway track torgedoes
1
and fusees in flassing kits of specified
construction.
8006
Authorizes transport of unlabeled packages of toy
2
paper or plastic CBPS complying with the
requirements of 173.100(p) and 173.109, in motor
vehicles with placards, when the gross weight of
the CBPS is 1000 pounds or more.
D-17
NUMBER
PURPOSE
REASON
8008
Authorizes manufacture, marking and sale of
1
non-DOT specification aerosol container consisting
of a glass bottle externally coated with plastic,
for shipment of compressed gases.
8017
Authorizes use of DOT Specification 3AX, 3AAX, or
2
3T cylinders for transportation of a flammable
sas.
8051
Authorizes manufacture, marking and sale of DOT
1
Specification reusable, blowmolded, polyethylene
containers, for transportation of corrosive
materials.
8053
Authorizes shipment of monoethylamine in inside
2
slass bottles/metel can, overpacked in DOT
Specification 12B fiberboard boxes.
8060
Authorizes use of non-DOT specification IMO Type 5
2
nortable tanks, for transportation of certain
nonflammable, liauefied sases.
8063
Authorizes use of a VBCUUM insulated DOT
2
Specification 41. welded cylinder, for
transportation of certain nonflammable gases.
8065
Authorizes shipment of certain Class A and Class B
2
explosives in non-DOT specification plywood boxes.
8077
Authorizes use of non-DOT specification steel
4
drums, for shipment of a flammable and corrosive
liquid.
8080
Authorizes transport of dry chromic acid in a DOT
1
specification 105A300W tank car which has been
converted to DOT Seecification 111A100W1; or a DOT
Specification 103AW tank car converted to DOT
Specification 103W.
8084
Authorizes transport of Class A explosives
1
containing more than 5% moisture in plastic tubes
overpacked in DOT seecification wooden or
fiberboard boxes.
8086
Authorizes transport of a cruise missile
2
containing hazardous materials.
D-18
NUMBER
PURPOSE
REASON
8096
Authorizes manufacture, marking and sale of
1
non-DOT specification steel cylinders for shipment
of certain nonflammable gases.
8099
Authorizes use of 2 non-DOT specification
2
corrugated fiberboard box with an inner
heat-sealed bas for the transportation of certain
poisonous solids.
8115
Authorizes manufacture, marking and sale of
1
non-DOT specification fiber reinforced plastic
hoop wrapped cylinder, for transportation of
certain nonflammable compressed gases.
8126
Authorizes use of non-DOT specification portable
2
tanks, for transportation of certain liquefied
etroleum sases and other gases classed as
flammable das and e flammable liquid.
8127
Authorizes use of a non-DOT specification
1
fiberboard drum for shipment of wet
nitrocellulose.
8131
Authorizes use of a non-DOT specification portable
2
tank made of Inconel 718 metal for shipment of a
nonflammable gas.
8141
Authorizes transport of individual cells and
1
modules consisting of three cells containing
lithium metal and thiongl chloride.
8151
Authorizes shipment of liquid hazardous materials
2
in five-sallon capacity removable head
polyethylene drums.
8152
Authorizes shipment of hydrofluoric acid,
1
solution, in an unlined DOT Specification MC-312
carso tank.
8156
Authorizes shipment of flammable sases in DOT
1
Sperification 39 cylinders UP to 225 cubic inches
in volume.
8162
Authorizes manufacture, markins and sale of 3
1
non-DOT specification cylinder for shipment of
certain nonflammable compressed gases.
D-19
NUMBER
PURPOSE
REASON
8167
Authorizes shipment of a chromic acid solution in
2
composite packaging consisting of B non-DOT
specification fiberboard outer box and expanded
polystyrene/glass bottle inner packasing.
8168
Authorizes manufacture, marking and sale of
1
non-NOT specification fully removable head
polyethylene drums, for shipment of certain
corrosive solids and bulid oxidizers.
8175
Authorizes shipment of benzoyl peroxide, wet, in a
2
plastic lined DOT Seecification 21C fiber drum,
without an inside polyethylene container.
8178
Authorizes use of a non-DOT specification
1
composite cylinder for a compressed nonliquefied
SES.
8180
Authorizes use of 3 non-DOT specification steel
1
drum for shipment of ? specifid corrosive material
and a flammable liquid.
8184
Authorizes shipment of trinitrotoluene in a
1
non-DOT specification multi-wall paper
polsethylene jute composite bas with net weight
not exceeding 100 pounds.
8194
Authorizes use of = fiberboard box complying with
2
DOT Speecification 12B (except for closure method
and its one-piece, die cut design) for shipment of
liquid organic peroxides.
8195
Authorizes use of non-DOT specification metal
2
drums 85 outside containers in lieu of prescribed
DOT specification fiberboard or wood containers.
8196
Authorizes use of 8 non-DOT specification portable
1
tank for the transportation of certain compressed
gases.
8207
Authorizes shipment of certain corrosive liquids,
2
n.o.s., in B one-quart tin can, placed in è molded
polsethylene liner, overpacked in a modified 28
gause DOT Specification 37A 2-gallon drum.
8208
Authorizes shipment of liquid propellant samples,
5
frozen, in non-DOT specification plywood boxes.
D-20
NUMBER
PURPOSE
REASON
8209
Authorizes carriase of Class A, B, and C
1
explosives not permitted for air shipment or in
Quantities greater than those prescribed for air
shipment.
8213
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying
generally with DOT Seecification MC-307/MC-312
except for bottom outlet valve variations, for
transportation of flammable or corrosive waste
liquids or semi-solids.
8214
Authorizes transport of inflators and modules for
1
passive restraint systems for use in automobiles,
8215
Authorizes shipment of certain identified Class A,
3
B. and C explosives in non-DOT specification
containers.
8220
Authorizes use of non-DOT specification small,
1
high pressure cylinders of welded construction for
sircraft use in the transportation of nonflammable
compressed gases.
8221
Authorizes use of non-DOT specification high
3
pressure cylinders of welded construction for
military missile systems use only.
8225
Authorizes USE of 3 non-DOT specification
2
rotationally molded, cross-linked polyethylene
portable tank for the shipment of corrosive
liquids and an oxidizer.
8228
Authorizes transport of packages containing not in
4
excess of 35 grams of one type of explosive
material or one explosive device, not exceeding 35
grams, in any one package
8230
Authorizes shipment of certain oxidizers in
1
non-DOT specification containers.
8232
Authorizes use of 2 non-DOT specification purtable
2
tank for the transportation of certain compressed
sases.
8236
Authorizes shipment of a passive restraint system,
1
and the inflator therefore, containing B Class R
explosive 85 a flammable solid.
D-21
NUMBER
PURPOSE
REASON
8238
Authorizes shipment of arsenical flue dust in
2
non-DOT specification packaging.
8239
Authorizes use of non-DOT specification containers
1
for the shipment of nonflammable sases.
8244
Authorizes shipment of various flammable,
1
combustible, and corrosive materials in lined
marine portable tanks.
8248
Authorizes shipment of various corrosive liquids
2
in a modified DOT Specification 15C wooden box,
compartmented to accommodate four (4) inner glass
bottles, each secured in an aluminum canister.
8249
Authorizes hazardous materials, which are required
1
to bear the POISON label, to be transported
without the label when shipped in prescribed
packaging.
8255
Authorizes use of a non-DOT srecification cylinder
2
for shipment of certain nonflammable gases.
8256
Authorizes shipment of stabilized sulfur trioxide
1
in DOT Specification 105A100W and 111A100W2 tank
cars equipped with standpipe electrical heaters
and a modified safety relief device.
8264
Authorizes shipment of certain solid propellant
1
explosives (Class R) and smokeless powders for
small arms (flammable solids) in non-DOT
specification fiber cans or tubes packed in
fiberboard boxes.
8265
Authorizes transport of certain solid propellant
1
explosives in non-DOT specification fiber tubes
packed in telescoping DOT Specification 12B
fiberboard buxes, and certain smokeless powders
for small arms, in DOT Specification 21C fiber
drums packed in fiberboard boxes.
8273
Authorizes transport of a passive restraint
1
module, and the inflator therefore, containing a
Class B explosive 35 a flammable solid.
8278
Authorizes use of a non-DOT specification
1
container for specified flammable gases and
liquids.
D-22
NUMBER
PURPOSE
REASON
8287
Authorizes shipment of a corrosive liquid in 3 DOT
2
Specification 6D/2SL composite container or a DOT
Specification 34 drum equipped with B buns vent.
8301
Authorizes use of a 30-gallon capacity DOT
2
Specification 34 container for the transportation
of certain flammable, corrosive, and Poison B
liquids, and liquid organic peroxides
8307
Authorizes shipment of non-eyrotechnid mixture of
2
certain corrosive materials, 985 and 80 explosive
charge in a non-DOT specification container.
8348
Authorizes manufacture, marking and sale of
2
non-DOT specification cargo tanks complying
generally with DOT Seecification MC-312 except for
bottom outlet valve variation, for transportation
of flammable or corrosive waste, liquids or
semi-solids.
8354
Authorizes use of a non-DOT specification portable
2
tank for the transportation of certain flammable
liquids and flammable gases.
8362
Authorizes shipment of batteries containing
1
lithium metal and thiongl chloride in fiberboard
boxes overpacked in wooden boxes.
8363
Authorizes shipment of certain identified solid
1
sropellant explosives.
8377
Authorizes transport of devices described as
2
detonating fuzes, Class C explosives, in
fiberhoard boxes inside wooden boxes.
8388
Authorizes shipment of liquid hazardous materials
2
in is five-sallon capacity removable head
polyethylene drum.
8390
Authorizes shipment of 95%-98% sulfurio acid in
2
DOT Specification 2F polyethylene bottles
overpacked in DOT Specification 12A80 fiberboard
boxes.
8396
Authorizes transport of a flammable liquid which
2
is also an organic peroxide in DOT Specification
MC-307 and MC-312 carso tanks.
D-23
NUMBER
PURPOSE
REASON
8407
Authorizes transport within plant over public
1
highway via fork-lift trucks, waste residues,
without shipping papers, contained in non-DOT
specification portable tanks.
8426
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying with
DOT Specification MC-307/312 with certain
exception for transport of liquid and semi-solid
waste materials.
8439
Authorizes manufacture, marking and sale of
2
non-DOT specification cylinders complying with DOT
Specification 4DS, with certain exceptions, for
shipment of various nonflammable compressed gases.
8445
Authorizes shipment of various hazardous
5
substances and wastes packed in inside plastic,
glass, earthenware or metal containers, overpacked
in B DOT Sperification removable head steel, fiber
or polyethylene drum, only for the purposes of
disposal, repackasing or reprocessing.
8451
Authorizes transport of not more than 25 grams of
1
hish explosives and pyrotechnic materials in a
special shipping container.
8453
Authorizes use of non-DOT specification carso
2
tanks and DOT Specification MC-306, MC-307, or
MC-312 stainless steel cargo tanks to transport
blasting agent.
8465
Authorizes manufacture, markins and sale of
2
non-DOT specification plastic bas (comparable to a
DOT Specification 44F), for shipment of ammonium
nitrate fertilizer.
Authorizes manufacture, marking and sale of
2
8478
non-DOT specification carso tanks complying with
DOT specification MC-307/312 with certain
exceptions, for transportation of liquid and
semi-solid waste.
8487
Authorizes manufacture, markins and sale of
2
non-DOT specification fiber reinforced plastic
aluminum lined full composite cylinders, for
shipment of certain nonflammable compressed gases.
D-24
NUMBER
PURPOSE
REASON
8494
Authorizes use of DOT Specification MC 307 cargo
2
tanks equipped with sight glass sauses.
8495
Authorizes manufacture, marking and sale of
2
non-DOT specification spherical containers similar
to DOT Seecification 4DS for shipment of
bromotrifluoromethane pressurized with nitrosen.
8498
Authorizes use of 2 non-DOT specification 55
2
sellon polgethylene Specification 34 type
packasing.
8510
Authorizes shipment of salt coated masnesium
2
granules in 2 non-DOT specification container.
8516
Authorizes shipment of ammonium
2
nitrate-fertilizer, classed 35 an oxidizer and
ammonium nitrate-fuel oil, classed as a blasting
agent to be stowed in the same hold or compartment
aboard ship.
8518
Authorizes manufacture, markins and sale of
2
non-DOT specification carso tanks complying
generally with DOT Specification MC-307/312 except
for bottom outlet valve variations, for
transportation of flammable or corrosive waste
liquids or semi-solids.
8519
Authorizes stowage of motor vehicles containing
2
sasoline, classed 35 a flammable liquid in same
carso compartment with other hazardous materials
or specially eQuipped roll-on-roll-off carso
vessel.
8520
Authorizes 'pipe test" in lieu of "fire test" for
1
blastins agents that will be packaged in drum size
containers not to exceed 55 gallons.
8522
Authorizes manufacture, markins and sale of
2
non-reusable molded expanded polystyrene cases
similar to DOT-33A except they will incorporate 6
cavities to contain a total of six 5-pint bottles.
8523
Authorizes shipment of various flammable and
2
non-flammable compressed sases in non DOT
specification IMCO Type 5 portable tanks.
D-25
NUMBER
PURPOSE
REASON
B526
Authorizes shipment of flammable liquids and/or
2
flammable Bases in temperature controlled
equipment.
8536
Authorizes an increased weight limitation for a
2
12B carton from 65 pounds to 80 pounds with the
dry weight of material not to exceed 50 pounds for
shipment of benzoyl peroxide.
8539
Authorizes carriage of certain Class A, B and C
1
explosives that are not permitted for air shipment
or are in Quantities greater than those prescribed
for shipment by air.
8540
Authorizes shipment of oxygen candles packaged in
5
specially designed metal containers.
8547
Authorizes shipment of phosphorous oxychloride in
2
prescribed tank cars constructed of Type 316
stainless steel.
8549
Authorizes manufacture, marking and sale of
2
certain non-DOT specification carso tanks
complying with DOT Specification MC-307/MC-312
except for bottom outlet valve variations, for
transportation of liquid and semi-solid waste
materials.
8551
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying
generally with DOT Seecification MC-307/312 except
for bottom outlet valve variations and certain
other features, for transportation of flammable,
corrosive, or poisonous waste liquids or
semi-solids.
8552
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying
generally with DOT Specification MC-307/MC-312
except for bottom outlet valve varistions, for
transportation of flammable or corrosive waste
liquids or semi-solids.
8554
Authorizes transport of propellant explosives and
1
blasting agents, in DOT Specification MC-306,
MC-307, and MC-312 carso tanks.
D-26
NUMBER
PURPOSE
REASON
8555
Authorizes shipment of 2 large rocket motor
1
segment on a special hishway vehicle.
8556
Authorizes use of non-DOT specification portable
2
tanks for shipment of liquefied hydrosen.
8558
Authorizes transport of a pharmaceutical described
4
as an initiating explosive in a non-DOT
specification polyethylene pail, overpacked in a
15-gallon DOT Specification 37A steel drum.
8561
Authorizes manufacture, marking and sale of
2
non-DOT specification stainless steel cylinders
similar to a DOT Seecification 3HT, for shirment
of oxysen.
8569
Authorizes shipment of 6.6 gallons of hydrazine,
1
aQueous solution in non-DOT specification F-16
emergency fuel tanks.
8570
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded,
cross-linked polyethylene portable tank, for
shipment of corrosive liquids and an oxidizer.
8571
Authorizes shipment of various flammable liquids
2
packaged in 2 DOT Specification 12A80 corrugated
fiberboard box with two inside metal containers
not over 10-liter capacity each.
8573
Authorizes manufacture, marking and sale of
2
non-DOT specification polyethylene bottles for
shipment of certain oxidizers, overpacked in a DOT
Specification 12B fiberboard box.
8577
Authorizes shipment of certain alkaline corrosive
2
liquids 0.0.5.1 in ? two Quart polyethylene
bottle, placed in a molded polyethylene liner,
overpacked in 3 DOT Seecification 37C steel drum.
8579
Authorizes shipment of ammonium nitrate fertilizer
2
in strapped or stretch wrapped palletized loaded
bags aboard cargo vessel exempt from spacing
criteria for bass and location.
8582
Authorizes transport of railway track torpedoes
1
and fusees packed in metal kits, in motor vehicles
by railroad maintenance crews as non-resulated
rail carrier equipment.
D-27
NUMBER
PURPOSE
REASON
8602
Authorizes manufacture, marking and sale of
2
non-DOT specification vaccum insulated portable
tanks for shipment of argon, nitrosen and oxysen.
8606
Authorizes shipment of monomethylamine anhydrous,
2
classed 85 B flammable sas in non-DOT
specification IMCO Type V portable tanks.
8609
Authorizes manufacture, marking and sale of
2
non-DOT specification removable head steel drums
complying with DOT Specification 17H, for shipment
of Poison B material in the same vehicle with
foodstuff.
8614
Authorizes carriage of certain Class A, B and C
1
explosives that are not permitted for air shipment
or are in Quantities greater than those prescribed
for shipment by sir.
B620
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying
generally with DOT Specification MC-307/MC-312
except for boltom outlet valve variations, for
transportation of flammable or corrosive waste
liquids or semi-solids.
8621
Authorizes loading of ammonium nitrate mixtures
5
containing more then 60% ammonium nitrate with no
organic coating contained in combustible
packagings on a break-bulk basis at a non-isolated
facility.
8645
Authorizes shipment of a viscous oxidizing
2
material in DOT Seecification MC-307/311 insulated
tank motor vehicles at ambient temperature,
8650
Authorizes use of 2 non-DOT specification steel
2
portable tank for shipment of motor fuel antiknock
compound.
8651
Authorizes transport of nitrosen tetroxide and
2
monomethylhydrazine in separate tanks mounted on a
motor vehicle chassis
B667
Authorizes transport of steel encapsulated sources
2
containing Type B Quantities of Cesium 137,
contained in calibrated radiolosical instruments
which do not meet all current testing
requirements.
D-28
NUMBER
PURPOSE
REASON
8673
Authorizes limited shipments of inhibited
5
hydrochloric acid solution in a DOT Specification
60 rubber lined portable tank.
8678
Authorizes use of non-DOT specification IMCO Type
2
V portable tank, for shipment of flammable and
nonflammable gases.
8684
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks constructed in
accordance with DOT Specification MC 331 with
certain exceptions, for the shipment of
nonflammable gases.
8689
Authorizes manufacture, marking and sale of a
2
non-DOT specification oil well sampling device for
the shipment of various compressed sases, n.o.s.
8691
Authorizes shipment of aluminum chloride
2
contaminated with phossene, in rackages presently
authorized under Section 173.245b(a)(1), (4), (8),
(9), (10).
8692
Authorizes shipment of sodium persulfate in
2
collamsible polyethylene-lined, woven
polypropylene bass having a capacity of
approximately 2,200 pounds each.
8693
Authorizes shipment of sodium, metal dispersion in
2
organic solvent in DOT Seecification 4BW240
cylinders.
8698
Authorizes menufacture, marking and sale of
2
non-DOT specification portable tanks for shipment
of non-eressurized liquid nitrosen.
8706
Authorizes manufacture, markins and sale of
2
non-DOT specification carso tanks complying
generally with DOT Seecification MC-307/MC-312
except for bottom outlet valve variations, for
transportation of flammable or corrosive waste
liquids or semi-solids.
8708
Authorizes use of non-DOT specification steel
4
drums (overeacked, polletized and containerized)
for shipment of a Class B poison.
D-29
NUMBER
PURPOSE
REASON
8710
Authorizes shipment of an organic peroxide classed
2
35 a flammable liquid, in a DOT Specification
MC-307/312 cargo tank equipped with temperature
and pressure sensins devices.
8716
Authorizes multi-trip use of DOT Specification 170
3
steel drums for shipment of lithium metal, insots,
immersed in oil.
8718
Authorizes manufacture, marking and sale of
2
non-DOT spucification limited cycle life,
fiberglass reinforced plastic cylinders, for
shipment of verious non-flammable compressed
sases.
8720
Authorizes manufacture, marking and sale of
2
non-DOT specification non-reusable welded steel
cylinders similar to DOT Specification 39, for
shipment of various non-flammable gases.
8723
Authorizes use of non-DOT specification motor
5
vehicles for bulk shipment of certain blasting
agents.
8725
Authorizes manufacture, marking and sale of
2
non-DOT Specification fiber reinforced plastic
hoor wrapped cylinders, for shipment of certain
compressed gases.
8732
Authorizes shipment of monoethanolamine, classed
2
as a currosive material in DOT Seecification
MC-306 cargo tanks constructed of steel and
aluminum.
8735
Authorizes manufacture, markins and sale of
2
non-DOT specification removable head polgethylene
drums for shipment of corrosive liquids.
8742
Authorizes manufacture, marking and sale of
2
non-DOT seecification cargo tanks complying
generally with DOT Specification MC-307/MC-312
except for bottom outlet valve variations, for
transportation of flammable or corrosive waste
liquids or semi-solids.
8748
Authorizes shipment of boron trifluoride, classed
2
85 a nonflammable 985 in non-DOT specification
containers when shipped as a component of a
radiation detector.
D-30
NUMBER
PURPOSE
REASON
8750
Authorizes manufacture, marking and sale of
2
non-DOT specification girth welded steel
cylinders, for shipment of certain nonflammable
gases,
8751
Authorizes shipment of various corrosive waste
2
liquids or semi-solids in non-DOT specification
cargo tanks similar to DOT Specification MC-312
except for bottom outlet valve variations.
8757
Authorizes manufacture, marking and sale of
2
non-DOT specification stainless steel cylinders,
for shipment of compressed gases.
8758
Authorizes manufacture, markins and sale non-DOT
2
specification portable tanks, for shipment of
certain nonflammable sases.
8760
Authorizes display of FLAMMABLE placards, showing
5
identification number (1993), on Barton Solvents,
Inc. carso tanks specified for the materials and
having six or more compertments when transporting
one or more hazardous material.
8763
Authorizes shipment of liquid hydrogen in non-DOT
2
specification cardo tank.
8767
Authorizes manufacture, marking and sale non-DOT
2
specification cylinders complying with DOT
Specification 39 with certain exceptions, for
shipment of helium, classed 85 nonflammable 985.
8772
Authorizes increased Quantity, not exceeding 5
3
sallon capacity, in packages of certain corrosive
liquids and flammable liquids that are corrosive,
when shipped via cardo aircraft only.
8802
Authorizes use of non-DOT specification IMO Type 5
2
portable tanks, for transportation of liquefied
compressed gases.
8812
Authorizes manufacture, marking and sale of
2
non-DOT specification five sellon metal containers
comparable to DOT Seecification 5L, for shipment
of gasoline, and gasohol, classed 85 flammable
liquids.
D-31
NUMBER
PURPOSE
REASON
8814
Authorizes manufacture, markins and sale of
2
non-DOT specification fiber reinforced plastic
full composite cylinders, for transportation of
certain flammable and nonflammable compressed
gases.
8815
Authorizes transport of certain blasting agents in
2
a cement mixer motor vehicle.
8837
Authorizes manufacture, marking and sale of
2
non-DOT specification portable steel tanks with a
polyethylene liner for shipment of a corrosive
liquid, n.o.s.
8839
Authorizes manufacture, markins and sale of
2
non-DOT specification rationally molded,
cross-linked polyethylene portable tank, for
shipment of corrosive liquids and an oxidizer.
8844
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks designed and
constructed in full compliance with DOT
Specification MC-307 OF MC-312 with certain
exceptions, for transportation of certain
hazardous materials.
8845
Authorizes transportation of charged oil well jet
2
perforating suns equipped with detonator and
arrest device, classed as explosive A and C.
8862
Authorizes shipment of propylene oxide, classed as
2
3 flammable liquid in DOT Specification 5P metal
drums.
8864
Authorizes transport of a corrosive liquid, n.o.s.
2
in existing non-DOT specification carso tanks
comparable to DOT Specification MC-312 except for
remote release valve and overturn protection.
8865
Authorizes shipment of helium, classed 85 a
2
nonflammeble 985 in a manifolded pressure vessel
system including 3 steel cylinder similar to DOT
Specification 39.
8877
Authorizes shipment of certain materials described
2
85 flammable liquids, corrosive, n.o.s. (corrosive
to skin only) and corrosive liquids, n.o.s., in
DOT-12B65 fiberboard boxes with inside glass
bottles having a capacity not to exceed
one-sallon.
D-32
NUMBER
PURPOSE
REASON
8888
Authorizes shipment of approximately 5,500 gallons
1
of compound cleaning, liquid in DOT Specification
37M steel drums with 2SL pulyethylene inside
container having 3 capacity exceeding the net
Quantity limitations for carso only aircraft.
8901
Authorizes shipment of chloropicrin, in
2
polyethylene bottles overpacked in non-DOT
specification triple-wall, corrugated fiberboard
boxes.
8904
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying
generally with DOT Specification MC-307/312 except
for bottom outlet valve variation and certain
other features. for transportation of falmmable,
corrosive or poisonous waste liquids or
semi-solids.
8906
Authorizes shipment of used, essentially empty
2
containers with residual amounts of carbofuran,
packed in a non-DOT specification double wall BC
flute corrugated fiberboard box.
8908
Authorizes shipment of dry chromic acid, in
2
non-DOT specification collapsible
polsethslene-lined, woven polypropylene bags.
8910
Authorizes use of non-DOT specification
2
rotationally molded, linear low density
polyethylene portable tank enclosed in a steel
case, for shipment of corrosive liquids.
8917
Authorizes transport ammonium nitrate prills in
2
large, lined steel container.
8921
Authorizes manufacture, marking and sale of
2
nonreusable non-DOT Specification steel Jacketed
polyethylene portable tanks, for transportation of
corrosive liquids.
8923
Authorizes transport of a flammable liquid which
2
is also corrosive in DOT Specification 51 portable
tanks.
8924
Authorizes manufacture, marking and sale of
2
non-DOT specification 55-gallon drums complying
with DOT-17H except for marking and the top head
is manufactured of 18 sause steel with only one
corrusation for shipment of paint classed as
flammable liquid.
D-33
NUMBER
PURPOSE
REASON
8930
Authorizes carriase of certain Class A, B and C
1
explosives that are not permitted for air shipment
or are in Quantities greater than those prescribed
for shipment by air.
8931
Authorizes shipment of sulfuric acid, classed as a
2
corroisve material in DOT Specification 111A100W2
tank cars equipped with bottom outlets.
8932
Authorizes use of carso tanks complying with DOT
2
Specification MC-307 and MC-312, for
transportation of organic peroxide solution.
8936
Authorizes shipment of 3 mixture containing 57%
2
chloropierin and 43% 1,3-dichloroproeene:
1,2-dichloropropane and related hydrocarbons,
respectively, by weight, in non-authorized DOT
Seecification 5B metal drums.
8937
Authorizes shipment of coated magnesium granules
2
in non-DOT specification collapsible flexible bas,
disposable bulk container.
8938
Authorizes manufacture, marking and sale of DOT
2
Specification 4L welded cylinders, for
transportation of nonflammable gases.
8942
Authorizes manufacture markins and sale of steel
2
Jacketed non-DOT specification rotationally
molded, cross-linked polyethylene portable tanks,
for shipment of corrosive liquids and an oxidizer.
8955
Authorizes transport of charged oil well suns with
2
detonators attached.
8958
Authorizes transport of limited Quantities of
3
black powder, classed as B flammable solid, in DOT
Specification 12H fiberboard boxes.
8960
Authorizes carriase of certain Class A, B and C
1
explosives that are not permitted for air shipment
or are in Quantities greater than those prescribed
for shipment by air.
8962
Authorizes manufacture, markins and sale of
2
non-DOT specification sirth welded stainless steel
cylinders, for transportation of 3 compressed 985.
D-34
NUMBER
PURPOSE
REASON
8965
Authorizes manufacture, marking and sale of
1
non-DOT specification fiber reinforced plastic
hoop wrapped cylinders, for shipment of certain
compressed gases.
8966
Authorizes shipment of sodium hypochlorite
2
solution in four one-sallon polyethylene bottles
enclosed in a bas of polyethylene film, packed in
a corrugated fiberboard box complying with DOT
Specification 12B except for hand holes authorized
in side panels of box.
8967
Authorizes shipment of 2 solid propellant
2
explosive, in a non-DOT specification fiberboard
tube, overpacked in a non-DOT specification
palletized metal case.
8968
Authorizes use of a non-DOT specification IMO Type
2
1 portable tank, for transportation of a flammable
solid.
8969
Authorizes shipment of certain rocket motors with
3
insniter installed.
8971
Authorizes use of non-DOT specification steel
2
cylinders of equal 01' greater integrity than those
currently authorized, for transportation of a
liquid oxidizer.
8977
Authorizes use of 3 non-DOT specification IMO-Type
2
5 portable tank, for transportation of liquefied
compressed gases.
8978
Authorizes transport of lithium cells containing
2
more than 12, but not more than 50, grams of
lithium metal, in non-DOT specification,
non-reusable, open head, steel drums.
8986
Authorizes transport of slurry blasting asent in
2
non-DOT specification stainless steel carso tanks.
8988
Authorizes transport of charged oil well suns as
2
Class C explosive when the net weight of explosive
material in the vehicle or vessel dues not exceed
200 pounds.
D-35
NUMBER
PURPOSE
REASON
8990
Authorizes manufacture, markins and sale of
2
non-DOT specification nonrefillable steel inside
cylinders, for transportation of nonflammable
compressed gases.
8991
Authorizes iransport of packages bearing the
2
DANGEROUS WHEN WET label, in motor vehicles which
are not placarded FLAMMABLE SOLID W.
8992
Authorizes transport of certain explosives not
1
permitted for air shipment or in Quantities
greater than those prescribed for air shipment.
8995
Authorizes use of non-DOT specification steel
2
portable tanks, for transportation of certain
nonpoisonous, nonflammable compressed gases.
8998
Authorizes shipment of nitrosen in hydraulic
2
accumulators.
8999
Authorizes transport of emergency oxygen
2
generators without marking, labeling, shipping
Papers or specification packaging.
9001
Authorizes manufacture, marking and sale of
2
non-DOT specification steel cylinders complying in
part with DOT Specification 3T cylinders, for
transfortation of certain nonflammable and
flammable gases.
9004
Authorizes manufacture, marking and sale of
2
non-DOT specification containers, for
transportation of flammable liquids and flammable
gases.
9010
Authorizes shipment of rocket motors, Class B
2
explosive in B specially designed container to be
shipped in a propulsive state.
9011
Authorizes certain DOT Seecification 5, 6 and 17
2
series drums constructed of stainless steel,
nickel or monel to be exempt from certain steel
drum test requirements, for shipment of those
commodities presently authorized for each drum.
9014
Authorizes manufacture, marking and sale of
2
non-DOT specification reusable, hish density,
blowmolded, polyethylene containers, for
transportation of certain corrosive liquids and
oxidizers.
D-36
NUMBER
PURPOSE
REASON
9015
Authorizes shipment of dry
1
trichloro-s-triazinetrione containing 90%
available chlorine in collapsible,
polyethylene-lined, woven polypropylene bass
having a capacity of not more than 2000 pounds
each.
9016
Authorizes manufacture, marking and sale of a
2
non-DOT specification fiber drum not to exceed 110
liter capacity, for shipment of certain flammable
liQuids and flammable solids.
9017
Authorizes shipment of hydrosen fluoride anhydrous
2
in non-DOT specification IMO Type portable tank
comparable to DOT Specification 51.
9019
Authorizes use of a marine portable tank, for
5
transportation of flammable, corrosive and
combustible liquids.
9023
Authorizes shipment of various refrigerant gases
2
in non-DOT specification IMO Type 5 portable
tanks.
9024
Authorizes shipment of various refrigerant gases
2
in non-DOT specification IMO Type 5 portable
tanks.
9026
Authorizes manufacture, marking and sale of
2
non-DOT seecification fiber drums of not over
75-sallon capacity, similar to DOT Specification
21C except that the top head is of molded
polyethylene and secured to the sidewall by a
lever lockins ring.
9027
Authorizes a one-time reuse of DOT Specification
3
37A containers for shipment of chromic acid, solid
and chromic acid mixture, classed as an oxidizer.
9030
Authorizes use of non-DOT specification metal,
2
sinsle trip, inside container, for shipment of a
nonflammable 385.
9034
Authorizes shipment of insecticide, liquefied sas
2
(containins no poison A or B material)
insecticide, liquefied sas (containing poison A
and R material), compressed 185, n.o.s., disilane
and disilane mixture in DOT Specification 3AL
cylinders.
D-37
NUMBER
PURPOSE
REASON
9036
Authorizes manufacture, marking and sale of
2
cylinders complying with Seecification 3AA except
for inspection of certain billets after parting,
for shipment of those sases presently authorized
in DOT Specification 3AA cylinders.
9040
Authorizes manufacture, marking and sale of
2
non-DOT specification fiber drums of not over
55-sallon capacity, lined or coated on the inside
with = plastic material, and having modified
non-removable top heads of steel or plastic, for
transportation of certain corrosive liquids.
9041
Authorizes shipment of devices, in specially
2
designed packagings, containing small amounts of
explosive described as detonating fuze, Class C.
9047
Authorizes use of copper-bearing (brass) valves in
2
DOT Specification cylinders and DOT Specification
5F drums containing ethylene oxide.
9048
Authorizes manufacture, marking and sale of
2
non-DOT specification containers, for
transportation of flammable liquids and sases.
9052
Authorizes manufacture, markins and sale of
2
non-DOT specification 225 gallon rotationally
molded polyethylene portable tanks, for shipment
of those corrosive liquids and hydrogen peroxide
presently authorized in DOT Specification 34 and
certain flammable liquids.
9054
Authorizes manufacture, marking and sale of
2
non-DOT specification 55-gallon polsethylene
containers, for shipment of certain corrosive
liquids, including those presently authorized in
DOT Seecification 34; hydrogen peroxides; classed
as an oxidizer, and ethyl and methyl alcohol,
classed 85 flammable
9059
Authorizes shipment of a fluorine Helium mixture
2
contained in appropriate DOT Secification
cylinders, to be described as fluorine mixture
classed 25 nonflammable 935.
9061
Authorizes shipment of small Quantity of a
2
flammable solid labeled Flammable Solid and
Dangerous When Wet but without a Flammable Solid W
placard on the vehicle.
D-38
NUMBER
PURPOSE
REASON
9062
Authorizes use of DOT Specification 57 carbon
2
steel portable tanks, for transportation of a
corrosive liquid.
9063
Authorizes use of non-DOT specification IMO Type 5
2
portable tanks, for transportation of
non-flammable compressed gases.
9064
Authorizes shipment of corrosive materials, in a
2
class container placed in a cushioned cylindrical
steel overpack, which is then packed in a
cushioned plywood box, of which no more than four
can be overpacked in a compartmented wooden outer
box.
9066
Authorizes transport of an airhas gus generator as
1
flammable solid, in 2 box constructed of single
wall corrugated fiberboard with 311 inside
styrofoam container insert for shock absorption.
9072
Authorizes shipment of rocket motors, class B
2
explosive in specially designed outside
packasinss.
9074
Authorizes use of non-DOT specification metal,
2
single trie, inside containers, for transportation
of is nonflammable 985.
9078
Authorizes use of DOT Specification 57 stainless
2
steel portable tanks, for transportation of a
waste formic acid/phenol mixture.
9079
Authorizes use of carbon steel DOT Seecification
2
51 portable tanks, for transportation of a
liquefied compressed $85.
9082
Authorizes shipment of carbamate pesticide, solid,
2
n.o.s., Class B poison, in non-DOT specification
woven polypropylene hass not to exceed 2,200
pounds each.
9095
Authorizes shipment of a nonliquefied flammable
2
985, in e DOT Specification 4E240 aluminum
cylinder.
9101
Authorizes shipment of several rocket motors
2
having gross weight in excess of 172.102 by carso
aircraft only.
D-39
NUMBER
PURPOSE
REASON
9108
Authorizes transport of an initiating explosive in
2
a plastic has, racked in a DOT Specification 12H
fiberboard box.
9110
Authorizes shipment of sodium chlorate, in non-DOT
2
specification collapsible polyethylene-lined,
woven polypropylene bass.
9114
Authorizes transport of electron tubes containing
2
small amounts of radioactive material (Radium 226
or Krypton 85) without specific determination of
total activity or Transport Index for the package.
9116
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded,
cross-linked polyethylene portable tank enclosed
within 2 protective steel frame, for shipment of
corrosive liquids, flammable liquids or an
oxidizer.
9120
Authorizes use of a non-DOT specification pressure
2
vessel, for transportation of certain flammable
gases.
9129
Authorizes repairing, rebuilding, retesting,
2
markins and sale of any DOT Specification 4B, 4BA
and 4BW low pressure steel cylinders.
9130
Authorizes shipment of an oxidizer, n.o.s., in
2
polwethylene containers of not over 10 pounds
capacits each, overpacked in a non-DOT
specification corrugated fiberboard box as
prescribed in 49 CFR 173.217(c).
9138
Authorizes shipment of nitrosen in a fiber
2
reinforced plastic full composite cylinder without
a safety relief device.
9140
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded,
cross-linked polyethylene portable tanks, for
shipment of corrosive liquids, flammable liquids
or an oxidizer.
9141
Authorizes shipment of certain hand signal
2
devices, 35 B flammable solid instead of 2 class C
explosive.
D-40
NUMBER
PURPOSE
REASON
9142
Authorizes use of a non-DOT Specification IMO Type
2
5 portable tank, for transportation of liquefied
compressed gases.
9143
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tanks complying in
general with DOT Specification MC-307/312 except
for bottom outlet valve variations for shipment of
waste flammable, corrosive or poison R liquids or
semi-solids.
9144
Authorizes manufacture, markins and sale of large,
2
non-DOt specification collapsible
polsethylene-lined woven polypropylene bulk bags,
having = capacity of approximately 2,000 pounds
each, for shipment of oxidizers and corrosive
solids.
9149
Authorizes use of non-DOT specification IMO Type 1
2
portable tanks, for transportation of motor fuel
antiknock compound.
9150
Authorizes manufacture, markins and sales of
2
non-DOT specification rotationally molded,
cross-linked polyethylene portable tanks with
bottom outlet, for shipment of corrosive and
flammable liquids or an oxidizer.
9158
Authorizes shipment of solid waste materials
3
contaminated with beryllium oxide, in a non-DOT
specification roll-on, roll-off, bulk container.
9164
Authorizes manufacture, marking and sale of a
2
non-DOT specification steel portable tank of 345
sallon capacity, with removable head, for shipment
of waste paint and waste paint sludge.
9168
Authorizes manufacture, marking and sale of
1
specially designed composite type packaging, for
shipment of small Quantities of various flammable,
corrosive, and poison B liquids and solids shipped
without labels.
9169
Authorizes transport of a water reactive material
5
in vented freight shipping containers.
D-41
NUMBER
PURPOSE
REASON
9174
Authorizes use of non-DOT specification
2
cylindrical and spherical pressure vessels, for
transportation of helium and nitrosen.
9176
Authorizes manufacture, marking and sale of DOT
2
Seecification 4L cylinders, for transportation of
certain nonflammable gases,
9181
Authorizes transport of lithium metal and a
2
thiongl chloride solution in the same non-DOT
specification stainless steel vessel.
9192
Authorizes shipment of various liquefied
2
compressed sases classed 85 flammable 985 in DOT
Specification 4L-112 cylinders.
9198
Authorizes DOI, and other government agencies
1
under contract to DOI, to use aircraft which are
under exclusive direction and control of DOI for
periods of less than 90 days.
9220
Authorizes manufacture, marking and sale of
2
non-DOT specification collapsible flexible bas,
disposable bulk container, for transportation of
corrosive solids and oxidizers.
9222
Authorizes use of non-DOT specification metal
5
tanks, for transportation of a flammable liquid or
flammable solid.
9235
Authorizes manufacture, marking and sale of
2
non-DOT specification steel drums of 24-sause
thickness and six-gallon capacity, to be used in
place of 24 sause, five-sallon capacity, DOT
Seecification 17E steel drums, for transportation
of various hazardous materials.
9239
Authorizes manufacture, marking and sale of
2
non-DOT specification steel drums of 30-gallon
capacity complying with DOT Specification 17H,
except for 178.118-6, for shipment of traffic
paint classed as flammable liquid.
9254
Authorizes shipment of insecticides and liquefied
2
985 mixtures in inside nonrefillable aluminum
containers comparable to DOT Seecification 2Q,
with integral pressure relief system.
D-42
NUMBER
PURPOSE
REASON
9256
Authorizes shipment of new explosives under a
4
tentative hazard classification to test facilities
without marking them 85 laboratory samples and
without being accompanied by a Qualified
explosives handler.
9262
Authorizes transport of oil well cartridges
1
containing not more than 500 grains of high
explosive.
9265
Authorizes carriage of certain Class A, B and C
1
explosives that are not permitted for shipment by
air.
9271
Authorizes deviation from car separation
1
requirements, for transportation of Class A and R
explosives.
9275
To broaden the exceptions to specification
2
packasing, marking and labeling requirements for
certain ethyl alcohol formulations.
9277
Authorizes shipment of organic phosphate compound
2
mixture, dry, Class B poison, in non-DOT
specification five-ply kraft multiwall, laminated
bass of 50 pounds capacity having a minimum total
basis weight of 250 pounds,
9280
Authorizes use of DOT Specification MC-330 and
2
MC-331 - carso tanks, for transportation of
flammable liquids which are also corrosive
materials.
9281
Authorizes transport of cylindrical pellets of
2
densensitized RDX, in DOT Specification 12B65
fiberboard boxes.
9282
Authorizes shipment of trifluoroethylene, classed
2
as compressed 885, in DOT Seecification 110A800W
tanks.
9289
Authorizes shipment of certain herbicides in metal
1
or polyethylene portable tanks considered to be an
implement of husbandry, without shipping papers.
9295
Authorizes manufacture, markins and sale of
2
non-DOT specification toroidal pressure vessel
equivalent to 2 DOT Specification 39 cylinder, for
transportation of nonflammable, nonliquefied
gases.
D-43
NUMBER
PURPOSE
REASON
9302
Authorizes air transport of radioactive material
1
without transport index and separation distance
controls provided operations are in accordance
with safety instructions provided by DOE or DOE
contractor radiolosical safety personnel.'
9308
Authorizes shipment of a corrosive liquid, n.o.s.,
2
in DOT Seecification 2E polyethylene bottles
equipped with vented closures to be overpacked in
DOT Specification 12B fiberboard box.
9312
Authorizes shipment of Space Shuttle Orbiters
2
which contain small Quantities of explosives,
flammable liquids and poisons, and nonflammable
gases in non-DOT specification pressure vessels.
9317
Authorizes use of non-DOT specification skid
2
mounted portable tanks to be transported on public
hishway within company property.
9319
Authorizes DOT Specification 57 steel portable
5
tanks, for water treatment compounds or boiler
compounds, liquid that are not alkaline.
9327
Authorizes manufacture, marking and sale of
2
mechanical diselacement meter provers mounted on a
truck chassis or trailer, for shipment of
flammable liquids and seses.
9329
Authorizes transport of charged well casing jet
5
perforating suns, classed 85 explosive A or
explosive C.
9330
Authorizes use of non-DOT specification portable
5
tank of 1,000 to 2,000 gallon capacity, for
transportation of nitrosen refrigerated liquid.
9331
Authorizes shipment of sodium chlorite solutions,
2
in DOT Specification MC-306 and MC-307 carso
tanks.
9332
Authorizes transport of a solid explosive
2
dissolved in an ammonia solution 85 a flammable
solid, in DOT Seecification 34 polyethylene
containers or DOT Specification 3E pulyethylene
bottles, packed in DOT Seecification 15A wooden
boxes.
D-44
NUMBER
PURPOSE
REASON
9338
Authorizes use of DOT Specification 106A500X and
2
110A500W multi-unit tank car tanks without is sas
tight valve protection housing, for transportation
of a corrosive material.
9340
Authorizes manufacture, marking and sale of
2
polyethylene/fiberglass removable head salvage
drum of 90-gallon capacity for overpacking damaged
or leakins packages of hazardous materials, for
repackaging or disposal.
9343
Authorizes transport of lithium metal in stainless
2
steel DOT Specification portable tanks.
9344
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded, linear
medium-density polyethylene portable tanks, for
shipment of corrosive liquids.
9346
Authorizes setting of the brakes and blocking the
2
wheels of the first and last tank cars on UP to a
twelve tank car assembly, instead of each
individual car, when engaged in unloading crude
oil and petroleum.
9347
Authorizes manufacture, marking and sale of
2
non-DOT specification stainless steel cylinders,
for shipment of flammable and nonflammable gases
used for samplins purPoSes.
9348
Authorizes transport of a limited number of
3
certain lithium batteries on passenger carrying
aircraft.
9350
Authorizes use of a non-DOT specification seamless
2
molded biphenolic epoxy cylinder, for shipment of
a nonflammable $25.
9351
Authorizes manufacture, marking and sale of
2
non-DOT specification steel spheres, made in
compliance with DOT Specification 3E with certain
exceptions, for transportation of certain
nonliquefied, nonflammable compressed gases.
9352
Authorizes menufacture, marking and sale of
2
non-DOT specification container described as
mechanical displacement meter provers mounted on a
truck chassis or trailer, for transportation of
flammable liquids and flammable gases.
D-45
NUMBER
PURPOSE
REASON
9354
Authorizes transport of alcohol-wet nitrocellulose
2
in non-DOT specification fiber drums.
9355
Authorizes transport of 2 limited number of
3
certain lithium batteries on passenger carrying
aircraft.
9357
Authorizes use of non-DOT specification IMO Type 5
2
portable tanks, for transportation of liquefied
compressed gases.
9363
Authorizes use of non-DOT specification cylinders
2
manufactured from monel to DOT Specification 3A
with certain exceptions, for transportation of
certain flammable and nonflammable gases.
9364
Authorizes shipment of a parathion mixture,
2
liquid, in B DOT Specification 12P corrugated
fiberboard box containing two inside DOT
Specification 2U pulyethylene containers of 2-1/2
sallon capacity.
9367
Authorizes manufacture, marking and sale of lorse
2
non-DOT specification collapsible
polsethylene-lined woven polypropylene bulk buss
having B capacity of approximately 2000 pounds
each, and top and bottom outlets, for shipment of
corrosive solids and nitrates.
9371
Authorizes carriage of Class A, B and C explosives
2
that are not permitted for shipment by air, or are
in Quantities greater than those prescribed for
shipment by air.
9374
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded,
cross-linked polyethylene portable tank enclosed
within a protective steel frame, for shipment of
corrosive liquids, flammable liquids or an
oxidizer.
9377
Authorizes transport of hish explosives containing
2
more than 5% moisture in packagings without inner
plastic bass or other linings.
9380
Authorizes use of a non-DOT specification
2
container described 35 a mechnical displacement
meter prover mounted on B truck chassis, for
transportation of hydrocarbon products.
D-46
NUMBER
PURPOSE
REASON
9381
Authorizes transportation of a water reactive
2
solid, which evolves hydrugen slowly when wet, in
open packagings such 85 drums, hopper trucks and
sondola cars.
9386
Authorizes manufacture, marking and sale of
2
non-DOT specification pressure vessel comparable
to DOT Specification 3HT cylinder with certain
exceptions, for transportation of compressed
gases.
9387
Authorizes transport of an organic phosphate
2
compound pressurized with a nonflammable
compressed 985, in concentrations and Quantities
greater then now authorized in the resulations, in
DOT Specification 3B cylinders.
9388
Authorizes use of DOT specification tank cars
2
which have had the amount of liquefied ses loaded
into the tank measured by a meterins device.
9393
Authorizes manufacture, marking and sale of
2
non-DOT specification steel cylinders in
compliance with DOT Specification 39, with certain
exceptions, for transportation of nonflammable
gases.
9400
Authorizes manufacture, markins and sale of
2
non-DOT specification rotationally molded,
spherical polyethylene portable tank enclosed in a
steel skid unit, for shipment of corrosive
liquids, flammable liquids or an oxidizer.
9401
Authorizes use of non-DOT specification IMO Type 5
2
portable tanks, for trausportation of flammable
and nonflammable liquefied compressed gaes.
9402
Authorizes use of non-DOT specification IMO Type 5
2
portable tanks, for transportation of flammable
and nonflammable liquefied compressed gases.
9405
Authorizes manufacture, markins and sale of
2
non-DOT specification fiber reinforced rlastics
(FRP) cardo tank having from one to five
compartments and a design pressure of 3 psig, for
transportation of flammable liquids.
D-47
NUMBER
PURPOSE
REASON
9408
Authorizes transport of silicon tetrafluoride in
2
DOT Specification 3AAX cylinders.
9413
Authorizes transport of a chemical kit which
2
contains small amounts of hydrochloric acid and
zinc powder.
9414
Authorizes shipment of tetrafluoromethane in DOT
2
Specification 3AL aluminum cylinders.
9415
Authorizes manufacture, marking and sale of a
2
polyethylene drum of 30-gallon capacity conforming
with DOT Specification 34 except for having a
single opening of four-inch diameter, for shipment
of those hazardous materials authorized in DOT
Specification 34 and DOT Specification 21 drums.
9416
Authorizes shipment of orsanophosphorous
2
pesticide, liquid, in 2 DOT Specification 12P
fiberboard box containing two inside DOT
Specification 2U polvethylene containers of 2-1/2
gallons capacity.
9418
Authorizes manufacture, marking and sale of
2
non-DOT specification portable tank assemblies
manifolded together withing a frame and securely
mounted on E truck chassis, for transportation of
flammable and corrosive liquids.
9425
Authorizes transport of certain alkaline corrosive
2
solutions in the same vehicle with gold and silver
cyanide solutions.
9426
Authorizes manufacture, marking and sale of
2
five-sallou and six-sallon capacity removable head
molded solyethylene drums for transportation of
corrosive liquids and flammable liquids.
9428
Authorizes use of a DOT Specification 105A500W
2
tank car tank with B modified insulation system,
for transportation of a nonflammable 985.
9430
Authorizes menufacture, marking and sale of B
2
polyethylene/fiberslass removable head salvage
drum of 90-sallon capacity for overpackins damaged
or leaking packages of hazardous materials, for
repackasing or disposal.
D-48
NUMBER
PURPOSE
REASON
9431
Authorizes several types of explosives in the same
2
package, in Quantities greater than authorized by
49 CFR 173.87.
9433
Authorizes transport of flammable gases at
2
atmospherie pressure in gless bulbs not exceeding
one liter capacity, packed in DOT Specification
12A/12B fiberboard boxes.
9436
Authorizes manufacture, marking and sale of
2
non-DOT specification portable tanks for
transportation of nonflammable refrigerated
liquid.
9440
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded,
cross-linked polgethylene portable tanks enclosed
with a protective steel frame, for shipment of
corrosive liquids, flammable liquids or an
oxidizer.
9443
Authorizes shipment of class R rocket motors with
2
isniters installed.
9446
Authorizes stowage of flammable liquids with flash
2
points below 73 desrees Fahrenheit in holds or
compartments that are fitted with a gooseneck type
of vent head.
9449
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded,
cross-linked polyethylene portable tanks enclosed
with 8 protective steel frame, for shipment of
corrosive liquids, flammable liquids or an
oxidizer.
9450
Authorizes manufacture, markins and sale of
2
non-DOT specification cylinders made in compliance
with DOT Seecification 4B240ET with certain
exceptions, for trensportation of flammable and
nonflammable gaes.
9456
Authorizes use of DOT Seecification MC-330 and
2
MC-331 carso tanks, for transportation of certain
corrosive materials.
D-49
NUMBER
PURPOSE
REASON
9460
Authorizes transport of a Class A type 4 explosive
2
in wealed velostat bas containing not more than
one pounds of powder or pellets, packed in DOT
Specification 17C or 17H metal drums.
9462
Authorizes manufacture, markins and sale of
2
non-DOT specification portable tanks manifolded
together within a frame and securely mounted on a
truck chassis, for tronsportation of flammable and
corrosive liquids.
9464
Authorizes transport of a pest control device
2
which has dimensions exceeding those authorized in
49 CFR, in a fiberbord card and placed in a heat
sealed plastic bag.
9466
Authorizes shipment of carbamate pesticide, solid,
2
n.o.s.. classed 85 a poison R in paper bass
similar to DOT Specification 2D, overpacked in DOT
Specification 120 fibierboard box.
9467
Authorizes shipment of certain flammable solids,
2
oxidizers and corrosive materials to be excepted
from the access to mixed lading requirements of 49
CFR 1'177.834(k)
9478
Authorizes manufacture, markins and sale of
2
non-DOT specification cylinders conforming with
DOT Seecification 3AL for shape and certain tests
for shipment of nonflammable gases.
9480
Authorizes transport of tetrafluoromethane in DOT
2
Specification 3AL cylinders.
9481
Authorizes transport of PETN wet with 25% water in
2
Plastic bass packed in fibreboard boxes instead of
metal drums.
9485
Authorizes transport of an insecticide, liquefied
2
985 mixture in DOT Specification 4BA260 cylinders.
9486
Authorizes use of a non-DOT specification carso
5
tank designed and constructed in full compliance
with DOT Seecification MC-307/312, with
exceptions, for transeortation of a liquid and
semi-solid waste material.
D-50
NUMBER
PURPOSE
REASON
9488
Authorizes use of specially sealed specification
2
2R containers in concrete filled steel drums, for
one-time transport for disposal of not more than
500 milicuries of radium-226 in normal or special
form without each shipper keeping 8 package test
performance certification file.
9490
Authorizes ue of non-DOT specification IMO Type 5
2
portable tanks, for shipment of flammable and
nonflammable liquefied compressed gases.
9491
Authorizes transport of hexafluoroethane and
2
trifluoromethane in DOT Specification 3AL
cylinders.
9498
Authorizes shipment of potassium cyanide, solid,
2
and sodium cyanide, solid, in collapsible,
water-tisht, polsethylene-lined, woven
polspropylene bas, each having a capacity not
exceeding 2,205 pounds each.
9499
Authorizes manufacture, markins and sale of 3-1/2,
2
5, 5-1/2, and 6-gallon capacity DOT Specification
35 removable head polgethylene drums, for shipment
of corrosive and flammable liquids.
9505
Authorizes transport of wet benzoyl peroxide in
2
polyethylene containers, packed in DOT
Seecification 12B fiberboard boxes.
9506
Authorizes transport of flammable liquids and
2
corrosive liquids in the same outside packagings
when the corrosive liquids are not in metal cans,
packed in DOT Specification 12B fiberboard boxes.
9507
Authorizes use of a non-DOT specification full
1
removable head salvage cylinder of 45 sallon
capacity for overeackins damaged or leaking
packages of pressurized and non-pressurized
hazardous materials.
9512
Authorizes use of non-DOT sgecification cargo
2
tanks complying with DOT Seecification MC-307/312
except hottom outlet and each bottom inlet must be
equipped with an additional shut-off valve, blank
flanse or a sealing CBP, for shipment of licuid
and semi-solid waste material.
D-51
NUMBER
PURPOSE
REASON
9513
Authorizes transport of an organic phosphate
2
formulation in a bulk motor vehicle.
9515
Authorizes shipment of gasoline in a non-DOT
1
sperification carso tank equipped with external
self-closins shut off valves.
9524
Authorizes manufacture, marking and sale of
2
non-DOT specification steel drums, similer to
DOT-17E drums except for reduced diameter top and
bottom heads of 0.0330-inch minimum thickness (20
gauge) and with chimes of seven Ply construction,
to be used for certain hazardous materials.
9528
Authorizes transport of nonself propelled
2
Aerospace Ground Equipment with gasoline or
aviation fuel in the tanks.
9529
Authorizes shipment of carbon disulfide in DOT
2
Specification MC-312 carso tanks.
9530
Authorizes use of non-DOT specification IMO Type 5
2
portable tanks, for transportation of nonflommable
liquefied compressed gases.
9533
Authorizes manufacture, marking and sale of large,
2
collapsible polyethylene-lined woven polypropylene
bulk bags having a capacity of approximately 2200
pounds each, and top and bottom outlets, for
shipmet of corrosive solids and oxidizers (solids
only).
9536
Authorizes manufacture, marking and sale of
2
non-DOT specification carso tank, patterned after
the MC-307 or MC-312 specifications with certain
exceptions, for transportation of certain
hazardous materials.
9548
Authorizes use of a non-DOT seecification IMO Type
1
1 portable tank, for shipment of motor fuel
antiknock compound.
9549
Authorizes transport of oil well cartridges
2
containing more than 350 grains, but not more than
600 grains of Class A, type 3 explosive, 35 Class
C explosive, in DOT Specification 12H fiberboard
box.
D-52
NUMBER
PURPOSE
REASON
9552
Authorizes testing of DOT Specification 23G
2
cylindrical fiberboard box once a year instead of
one every six months.
9554
Authorizes manufactue, marking and sale of non-DOT
2
specification polyethylene/fiberglass reinforced
plastic (FRP) dual laminate composite drum, fully
conforming with DOT Specification 34 with
exceptions.
9555
Authorizes use of DOT Specification MC-330 and
2
MC-331 carso tanks for shipment of a poison B
liquid.
9571
Authorizes transport of not more than 5 siams of
1
an approved or unapproved explosive in a special
packaging essentially without regulation.
9573
Authorizes use of = surface binding material on
1
uranium ore in open tos rail cars as a means to
prevent loss of perticulates from the rail cars
instead of the normally required use of closed
transport vehicles.
9577
Authorizes shipment of reserve-activated
2
lithium/thionyl chloride IRSS battery modules
packaged in DOT Specification 19A wooden boxes.
9579
Authorizes use of a non-DOT specification motor
1
vehicle for bulk shipment of oxidizers.
9590
Authorizes shipment of a liquid mixture containing
1
67.7% Chloropicrin, a Class B poison, in DOT
Specification 5B steel drums, not exceeding
33-gallon capacity.
9593
Authorizes transport of ammunition for cannon
5
Class A explosives, and certain non-hazardous
materials aboard carso aircraft.
9596
Authorizes use of non-DOT seecification insulated
1
portable tank for tranportation of nonflammable
sases.
9599
Authorizes manufacture, markins and sale of
2
non-DOT sgecification portable tanks constructed
of 304 stainless steel with a carbon steel Jacket,
approximatele 4,000 gallon cupacity, for shipment
of arson, refrigerated liquid, classed as
nonflammable 985.
D-53
NUMBER
PURPOSE
REASON
9601
Authorizes shipment of liquid, 100% chloropricrin,
1
a Class B poison, in non-DOT specification
zinc-plated steel drums, not exceeding 26-sallon
capacity.
9603
Authorizes use of a non-DOT specification tank car
5
which conforms to DOT Specification 111A100W1
except for 3 thinner shell thickness in certain
areas and for devistions in length of welds used
in attaching bar pads.
9610
Authorizes transport of DOT Seecification 21C
2
fiber drums which contain not more than 5 grams of
smokeless powder essentially without resulation.
9617
Authorizes transport of 2 specially defined
2
detonating cord on the same motor vehicle with
Class A and Class C detonators.
9623
Authorizes transport of blasting agent or an
2
oxidizer in è DOT Specification MC-306 or MC-307
carso tank with a storage box containing Class A
explosives mounted directly behind the tractor
cab.
9626
Authorizes transport of welding machines
2
containing batteries in non-accessible places on a
motor vehicle.
9632
Authorizes use of non-DOT Specification IMO Type 5
2
portable tanks, for transportation of flammable
and nonflammable liquefied compressed sases.
9633
Authorizes transport by carso aircraft of a
5
propellant explosive and igniter, rocket motor,
which are forbidden for transportation by air and
non-resulated weapon components.
9642
Authorizes use of DOT Specification 106A500X and
2
110A500W multi-unit tank car tanks for a waste
liquid mixture that is corrosive to skin only.
9643
Authorizes transport of certain hazardous
2
materials over 0.3 miles of public highway
exempted from DOT requirements for package
marking, labeling, specification packaging and
segresation.
D-54
NUMBER
PURPOSE
REASON
9644
Authorizes manufacture, marking and sale of a DOT
2
Specification 23G cylindrical fiberboard box
tested once B year instead of every six months,
for shipment of certain Class A explosives.
9645
Authorizes manufacture, markins and sale of
2
non-DOT rotationally molded, cross-linked
polyethylene or linear low density polyethylene
portable tanks, enclosed within either a
protective steel frame or 2 foam-filled steel
reinforced outer case.
9648
Authorizes transport of a rocket motor with
1
isniter installed in a non-DOT specification
wooden box.
9652
Authorizes transport of specially packaged
2
detonators in DOT Specification 12B fiberboard
boxes.
9654
Authorizes shipment of hydrogen peroxide solution
2
exceeding 52% concentration, in aluminum drums
conforming to DOT Specification 44D except for
rollins hours.
9658
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationelly molded,
composite crosslinked or non-crosslinked
polyethylene and Teflon PTA plastic portable tank
for shipment of corrosive liquids, flammable
liquids or oxidizers.
9659
Authorizes manufacture, marking and sale of
2
non-DOT specification fiber reinforced plastic
(FRP) full composite (FC) cylinder, for
trensportation of certain flammable and
nonflammable compressed gases.
9662
Authorizes shipment of asricultural chemicals in
1
2.5 gallon capacity containers.
9663
Authorizes manufacture, marking and sale of
1
cylindrical steel, overpacks similar to DOT-37M
except well thickness is 25 gase instead of 24
gase and inner polyethylene drum meets DOT-2SL
except for marking, for shipment of those
hazardous materials authorized in DOT-37M/2SL.
D-55
NUMBER
PURPOSE
REASON
9664
Authorizes transport of a loser device containing
4
a smell Quantity of methane in BU passenser's
carry-on or checked hassage.
9666
Authorizes approximately 150 DOT Specifications
5
4BA240 and 4BW240 cylinders to be hydrostatically
retested every ten years, rather than every 5
years, when used solely for the shipment of
non-corrosive, metal alkyl solutions, for
transportation of a flammable liquid.
9671
Authorizes transport of nonliquefied ethylene in
2
DOT Specification 4BA240 cylinders.
9672
Authorizes shipment of metal a alkyl solutions in a
2
DOT Seecification MC-330 ro MC-331 cargo tank with
a filling/discharge opening that does not have a
remote self-closing internal valve.
9673
Authorizes manufacture, marking and sale of fiber
2
drums not to exceed 250 liter capacity, comparable
to DOT-21C except for the top and bottom heads
which are made of 0.48 mm steel sstead of 0.53 mm
(24 sause) steel, for shipment of those hazardous
materials, authorized in DOT-21C fiber drums.
9674
Authorizes battery plates containing lead peroxide
1
to be shipped when packaged in a pallet-shrink
WTBP configuration.
9675
To authorize shipment of approximately 100,000,
1
five gallon capacity DOT Specification 34 drums
containing hyprochlorite solution, classed 35 a
corrosive material which are inadvertenly marked
NA 1791 rather than the required UN 1791.
9676
Authorizes shipment of certain flammable liquids
1
contained in four inside glass bottles or PVC
costed glass bottles of one sallon capacity each,
overpacked in a corrugated fiberboard box
conforming to DOT Seecification 12B65 except for
handholes in the same side Panels of the box.
9677
Authorizes shipment of hydrochloric acid in
1
non-DOT specification bottles of one-gallon
capacity, overpacked no more than 60 to a
specially-desisned, heavy-wall cart, molded of
hish density polyethylene.
D-56
NUMBER
PURPOSE
REASON
9678
Authorizes use of dry bulk tank semi-trailers for
5
shipment of magnesium and calcium salt mixtures.
9679
Authorizes shipment of ammonium hydroxide, classed
5
as D corrosive material, in a six gallon capacity,
DOT Specification 2U polyethylene containers,
overpacked in a DOT Specification 12P fiberboard
box.
9681
Authorizes limited Quantities of Class A, Type 4
4
explosives, to be placed in special packaging not
prescribed in 49 CFR.
9683
Authorizes manufacture, markins and sale of
5
non-DOT seecification containers, for
transportation of flammable liquids and gases.
9685
Authorizes manufacture. marking and sale of
2
non-DOT specification roll on/roll off cylindrical
tank containers for transportation of certain
solidfied mixtures of waste flammable liquids
and/or corrosive materials.
9686
Authorizes manufacture, marking and sale of
1
non-DOT specification rotationally molded Teflon
PFA container of 20 liter capacity with
filament-wound fiberyless reinforcement, for
shipment of those flammable or corrosive liquids
autorized in DOT-34 and DOT-6D/2S or 2SL composite
packsings.
9688
Authorizes shipment of thiongl chloride, classed
2
as = corrosive material in non-DOT specification
bottles of "Teflon" PFA, rangins in size from 10
to 16 ounces capacity, overpacked in DOT
Specification 17H stainless steel drums, not to
exceed 54 bottles per drum.
9689
Authorizes drums containing dense of heavy
1
materials such 85 toluene diisocyanate, and other
hazardous materials not exceeding 12.09 pounds per
gallon, to be secured against movement in a
transport vehicle by the use of a fabric restraint
dunnase system when shipped by carso vessel.
9690
Authorizes manufacture, marking and sale of
2
non-DOT specification rotationally molded
crosslinked or non-crosslinked polyethylene
portable tank, for the shipment of corrosive
liquids, flammable liquids or an oxidizer.
D-57
NUMBER
PURPOSE
REASON
9691
Authorizes manufacture, marking and sale of 15
1
gallon steel overpacks similar to DOt-37M except
for slight reduction in wall thickness with
polyethylene liner meetins DOT-2SL except for
specification markings, for shipment of those
hazardous materials authorized in DOT-37M/2SL.
9692
Authorize use of DOT Specification 57 portable
1
tanks for shipment of a dual hazard (flammable
liquid/corrosive to skin only) material.
9694
Authorizes use of MC-331 cardo tank equipped with
2
angle valves and pressure relief valves not
presently authorized in the regulations.
9695
Authorizes transport of an ammonia solution in DOT
3
Specification 4AA480 cylinders which were charged
after the required retest date.
9696
Authorizes menufacture, marking and sale of
1
non-DOT rotstionally molded Teflon PFA container
of 100 liter capacity with filament-wound
fiberglass reinforcement and a high density
polyethylene overpack, for shipment of those
liquids authorized in DOT-34 and DOT-6D/25 or 2SL
composite packagings.
9697
Authorizes use of DOT Specification 105A300W and
3
105A400W tank car tank with the tank overdue for
retesting, for 3 one-time shipment of a waste
corrosive liquid.
9700
Authorizes use of a DOT Seecification 51 portable
1
tank having pressure relief devices with a
start-to-discharse pressure of 75 psig, for
transportation of flammeble, poisonous liquid.
9701
Authorizes manufacture, markins and sale of large,
2
collaesible pulyethylene-lined woven polypropylene
bulk bass havins a capacity of no more than 2500
pounds each, and top and/or bottom outlets, for
shipment of flammable and corrosive solids and
oxidizer (solids only)..
9702
Authorizes manufacture, markins and sale of a
2
non-DOT specification multi-wall kraft paper
pinch/seal has of 25-round and 50 pound net
construction for shipment of calcium nitrite, and
oxidizer, n.o.s.
D-58
NUMBER
PURPOSE
REASON
9703
Authorizes transport of a limited number of
3
certain lithium batteries on passenser-carryins
aircraft.
9704
Authorizes transport of small arms primers in DOT
1
Specification 23F fiberboard boxes.
9705
To authorize shipment of propyleneimine,
1
inhibited, classed BS 3 flammable liquid in DOT
Specification 51 portable tank.
9707
Authorizes transport of certain flammable liquids
1
in DOT Specification packaging without labelins.
9708
Authorizes shipment of magnesium metal pellets,
1
classed as a flammable solid, in DOT Specification
44C multiwell paper bass lined with plastic film.
9709
Authorizes manufacture, marking and sale of a
2
polyethylene, removable head salvage drum of
85-gallon capacity for overpacking of damaged or
leakins packases of hazardous materials or for
packing hazardous materialss that have spilled or
leaked for repackasing or disposal.
9710
Authorizes abbreviated markins of the one-way
3
travel time on the tank and on shipping papers.
9711
Authorizes shipment of a corrosive liquid in a
1
nylon-reinforced polyethylene bas of 5-liter (1.22
gallon) capacity which is placed in an inside
corrugated fiberboard carton with not more than
two cartons overpacked in a DOT Specification
12B30 corrugated fiberboard box.
9712
Authorizes transport of butadiene in a DOT
2
Seecification 105J400W tank car with a thermal
protection system not authorized in accordance
with 49 CFR.
9713
Authorizes manufacture, markins and sale of large,
2
collapible polyethylene-linked woven pulyprosylene
bulk bass having a capacity of spproximately 2000
pounds each, and top and bottom outlets, for
shipment of corrosive solids and oxidizers (solid
only).
D-59
NUMBER
PURPOSE
REASON
9714
Authorizes shipment of Bidrin" 8 Insecticide,
1
Classed as D Poison B liquid, in non-DOT
Specification high densits polyethylene
containers.
9715
Authorizes shipment of dicumsl reroxide, dry, or
1
organic peroxide, solid, insider polyethylene
polsethylene bags in Quantities of UP to 40
pounds, overpacked in a DOT Specification 12865
corrugated fiberboard box.
9716
Authorize manufacture, markins and sale of non-DOT
2
specification fiber reinforced plastic full
composite cylinder, for shipment of certain
falmmable and nonflammable compressed sases.
9717
Authorizes shipment of certain flammable liquids
1
in inside containers of us to 1 gallon capacity,
overpacked in B DOT Specification 21C fiber drum.
9718
Authorizes shipment of flammable and nonflammable
1
gases in a non-DOT specification portable tank
comparable to DOT Specification 51 portable tanks.
9719
Authorize carriase or certain Class A, R and C
1
explosives that are not permitted for shipment by
air, or in Quantities greater then those
prescribed for shipment by air.
9721
Authorize one-time shipment of special fireworks,
5
Class E: explosive, in non-DOT specification
fiberboard boxes without the proper markings.
9723
Authorizes shipment of "lab-packs' containing
1
cyanides and cyanide mixture with 'lab-packs'
containing acids and corrosive liquids in the same
transport vehicle.
9725
Authorizes one-time shipment of DOT Specification
3
105A300W tenk car to the nearest cleaning or
retrofit facility.
9727
Authorizes shipment of of 311 alkaline corrosive
1
liquid, n.o.s. in new or reconditioned DOT
Specification 17H steel drums.
D-60
NUMBER
PURPOSE
REASON
9728
Authorizes manufacture, marking and sale of
2
non-DOT specification containers described BS
mechanical displacement meter provers mounted on a
truck chassis or trailer.
9729
Authorizes shipment of corrosive materials in
2
stainless steel cylinders complying with all
reqvirements of DOT Specification 4BW except for
beins fabricated from Type 304L stainless steel.
9730
Authorizes use of super-insulated DOT
2
Seecification MC-338 carso tank for transportation
of flammable crsosenic liquid.
9731
Authorizes manufacture, markins and sale of DOT
2
Specification MC-338 cargo tanks for shipment of
liquid hydrogen with holding time tests performed
in a manner other than 35 prescribed in the
regulations.
9732
Authorizes certain detersent which are classed as
2
flemmable liquids for transport 85 combustible
liquids in DOT Specification MC-307 carso tanks.
9733
Authorizes manufacture markins and sale of DOT
2
Specification 35 polyethylene drums of six-gallon
capacity for the shipment of chromic acid mixture,
dry, or chromic acid, solid, classed as oxidizers.
9735
Authorizes the Dangerous Carso Manifest on cargo
1
vessels owned and operated by Hapag-Lloyd AG to be
retained in B location other than on or near the
bridge of the vessel while the vessel is in port.
9737
Authorizes transport of cerso aircraft of certain
5
Class A explosives which are forbidden for
shipment by air and certain Class C explusives.
9738
Authorizes shipment by cargo aircraft of acrolein,
5
inhibited, in DOT Specification 51 portable tanks
of 250 sallon capacity which exceeds the quantity
limitation of 49 CFR 172.101 table, column 6.
9741
Authorizes shipment of batteries palletized and
1
shipped BS 2 unit without means of protection from
any superimposed weight.
D-61
NUMBER
PURPOSE
REASON
9742
Authorizes shipment of methyl bromide liQuid in a
1
non-DOT specification portable tank meeting all
the requirements of B DOT Specification 51, with
exceptions.
9744
Authorizes shipment of benzosl peroxide, wet with
1
at least 30% water, classed 35 an organic
peroxide, in 2 DOT Seecification 12B65 fiberboard
box containing a bas with 31.5 pounds of material
(dry weight).
9746
Authorizes use of DOT Specification 3BN cylinders
1
for trensportation of hydrogen fluoride,
anhydrous.
9748
Authorizes manufacture, marking and sale of
2
non-DOT specification fiber drum of not over
75-gallon capacity, similar to DOT-21C except that
the Loe head is of molded polyethylene or
polypropylene and secured to the side wall by a
level locking rins, for transportation of various
hazardous materials.
9749
Authorizes shipment of 8 material containing a
1
hazardous substance without listing the name of
the hazardous substance on the shipping paper and
on the package when transported by private or
contract carriers.
9750
Authorizes transport of ammonium nitrate solution
2
containing not less than 13% water in DOT
Specification MC-307 insulated cargo tank or a DOT
Seecification MC-311 insulated cargo tank.
9751
Authorizes transport of a Class A explosive device
3
in limited Quantities as a Class C explosive.
9752
Authorizes shipment of motor fuel antiknock
1
compound, Class B poison, in a DOT Seecification
12B fiberboard box with inside packaging
consistins of an inner metal can, surrounded by
vermiculite and then hermetically sealed in an
outer metal can.
9753
Authorizes manufacture, marking and sale of
2
non-DOT specification pressure vessels for
shipment of helium, classed as a nonflammable 985,
in 8 missile sas storage system.
D-62
NUMBER
PURPOSE
REASON
9754
Authorizes manufacture, markins and sale of
2
non-DOT specification reusable, rotationally
molded, polyethylene container conforming with DOT
Specification 34 with exceptions for shipment of
certain corrosive liquids, flammable liquids,
Class F poisonous liquids and an oxidizing.
9755
Authorizes transport of packages of Class A
1
explosive which exceed the weight limitation in 49
CFR 173.65(a)(4), in a non-DOT specification
wooden box.
9756
Authorizes 3 one-way shipment of corrosive solids,
1
for disposal in four non-DOT specification steel
portable tanks.
9757
Authorizes shipment of non-DOT spccification steel
1
portable tanks containing corrusive solid, n.o.s.
to an approved disposal facility.
9759
Authorizes a one-time shipment of common
5
fireworks, Class C explosive, in non-DOT
specification fiberboard buxes with inner flaps
which do not meet and with no fiberboard flap
fill-in pieces.
9760
Authorizes transport of eight (8) DOT
5
Specification 21C fiberboard drums, each
containing a net weight of 75 pounds of a
propellant explosives, solid, Class R, aboard
carso aircraft.
9761
Authorizes manufacture, marking and sale of
5
non-DOT specification welded stainless steel
cylinders patterned after DOT-4DS with exceptions,
for transportation of nonflammable sases.
9763
Authorizes shipment of certain hazardous materials
1
in DOT Seecification 3BN cylinders, a
specification cylinder not presently authorized.
9765
Authorizes shipment of ethylene oxide, classed 85
1
a flammable liquid, contained in aluminum
cartridges and cushioned in molded expanded
polystyrene trays, overpacked in a DOT
Specification 12815 corrusated fiberboard box.
D-63
NUMBER
PURPOSE
REASON
9766
Authorizes use of non-DOT specification fiber
1
drums containing not more than 9 TOW M114 Rocket
Motors.
9769
Authorizes use of lab-packs for transportation by
1
vessel, partially exempts lab-packs from
segresation requirements.
9770
Authorizes reuse of DOT Specification 17H drums of
1
55-gallon capacity for multiple shipments of
sodium methylate, classed as a flammable solid,
without subjectins drums to reconditionins
requirements.
9772
Authorizes use of a non-DOT srecification
1
torodiel shape pressure vessel for transportation
of specific hazardous materials.
9775
Authorize manufacture. marking and sale of a
2
polyethylene, removable head salvage drum of
85-gallon for overpacking of damaged or leskins
packages of hazardous materials of no greater than
55-dallon or for packing hazardous materials that
have spilled or leaked, for repackaging or
disposal.
9776
Authorizes a one time shipment of apaproximately
5
782 non-DOT specification 30 sallon capacity,
metal drums containing lithium metal.
9777
Authorizes shipment of 2 15 percent solution of
2
potassium permansenate maintained at 165 degrees
Fahrenheit, in a DOT Seecification MC-312 carso
tank.
9779
Authorizes manufacture, marking and sale of
2
non-DOT specification portable tanks and
manifolded together within a frame and securely
mounted on a truck chassis.
9780
Authorizes shipment of flammable liquids, n.o.s.,
1
classed as flammable liquid, in three DOT
Seecification 2U polyethylene containers of
two-sallon capacity each, overpacked in a DOT
Specification 12P corrugated fiberboard box.
D-64
NUMBER
PURPOSE
REASON
9781
Authorizes use of B non-DOT specification full
1
opening head, steel salvage cylinder for
overpacking demased or leaking chlorine cylinders.
9782
Authorizes shipment of Potassium metal in non-DOT
1
specification container.
9783
Authorizes manufacture, marking and sale of large
2
collapsible polyethylene-lined woven polypropylene
bulk bass having a capacity of approximately 2260
pounds each, and top and bottom outlets, for
shipment of flammable solids, oxidizing materials,
poison R solids and corrosive solids.
9784
Authorizes manufacture, markins and sale of DOT
2
Seerification 4BA or 4BW cylinders fitted with
rubber footrinss attached by welding after heat
treatment, for transportation of propane.
9790
Authorizes manufacture, marking and sale of
2
non-DOT specification welded cylinders conforming
with the DOT Specification 4L except that the
container is made of Type 316L stainless steel.
9792
Authorizes menufacture, markins and sale of a
2
non-reusable expanded polystyrene case similar to
DOT-33A, except it will have six cavities to
contain not more than six five-pint or six 20
ounce bottles, for shipment of those commodities
authorized by in = DOT-33A packasing.
9794
Authorizes transport of rocket ammunition with
4
explosive projectile, Class A explosive in
carso-onls aircraft, although it is forbidden for
transportation by sir.
9795
Authorizes carriage of small cuantities of a
4
flammable liquid in safety lamps in the passenger
cabin of an aircraft.
9796
Authorizes a one-time shipment of rocket
5
ammunition with explosive projectile, Class A
explosive, Carso-only aircraft, although it is
forbidden for transportation by sir.
9797
Authorizes one-time shipment of a nonflammable
3
985, in 8 nonrefillable, non-DOT specification
container.
D-65
NUMBER
PURPOSE
REASON
9798
Authorizes shipment of rocket ammunition with
5
explosive projectile, Class A explosive,
carso-only aircraft, although it is forbidden for
transportation by air.
9799
Authorizes shipment of rocket ammunition with
5
explosive projectile, Class A explosive, and
rocket ammunition with incrt projectile, Class B
explosive, which are forbidden for transportation
by air.
9800
Authorizes a onc-time shipment of a limited
3
Quantity of Class A, Type 4 explosive, to be
placed in special packaging not prescribed in 49
CFR.
9801
Authorizes relesting of DOT Seecification
5
111A100W2 tank car tanks, over ten years of aye,
with sulfuric acid in lieu of water.
9802
Authorizes carriage of certain Class A, B and C
1
explosives that are not permitted for shipment by
air, or are in Quantities sreater than those
prescribed for shipment by air.
9803
Authorizes carriage of certain Class A, B and C
1
explosives that are not permitted for shipment by
air, or are in quantities greater than those
prescribed for shipment by zir.
9804
Authorizes menufacture, marking and sale of
2
non-DOT specification rotationally molded,
polyethylene portable tank enclosed in a steel
frame, for the shipment of corrosive materials,
flammable liquids, or an oxidizer.
9806
Authorizes manufacture, marking and sale of large,
2
collapsible polyethylene-lined woven polypropylene
bulk bass having a capacity of spproжimately 2200
pounds each, and tup and bottom outlets, for
shipment of corrosive solids and nitrates.
9808
Authorizes shipment of ammonium nitrate-potassium
1
nitrate, identifed as ANKN 90/10, classed as an
oxidizer, in E moisture resistant, multi-ply paper
bag.
D-66
NUMBER
PURPOSE
REASON
9809
Authorizes use of B non-DOT specification
1
container described as a mechanical displacement
meter prover mounted on a truck, for
transportation of flammable liquids.
9810
Authorizes transport of a laser device containing
1
a small Quantity of methane in a non-DOT
specification container.
9811
Authorizes shipment of non-DOT specification steel
1
portable tanks containing SCTBP metal pipe that is
contaminated with asbestos and poison B materials
for disposal.
9813
Authorizes packages of tear ses grenades in DOT
1
Specification 32A metal, military type ammunition
boxes.
9815
Authorizes = one-time shirment of Para cresol,
5
classed 85 a corrosive material in ? DOT
Specification 111A60W1 tank car (GATX 19808)
equipped with on anti-shift bracket welded
directly to the tank shell without the required
reinforcement pad.
9816
Authorizes shipment of hypochlorite solution, more
5
then 7 percent evailable chlorine by weight, in
non-DOT spsecification cargo tanks.
9818
Authorizes use of a DOT Specification 105A500W
3
tank car tank with the tank and safety relief
valves overdue for retesting for B one-time
shipment of chlorine.
9822
Authorizes shipment of poisonous liquid R&D
1
Samples in packasins conforming to 49 CFR
173.331(b)(1).
9824
Authorizes use of accumulators which deviate from
1
the required test criteria in 49 CFR 173.306(f)
for shipment of compressed sas mixtures.
9828
Authorizes shipment of azinphos methyl, mixture,
1
solid, classed as poison B, in water soluble
packets (PVA) inside lined chipboard cartons
overpacked in DOT Specification 12B65 fiberboard
boxes.
D-67
NUMBER
PURPOSE
REASON
9834
Authorizes a one-time shipment of an insulated
4
stainless steel dewar containing liquid nitrosen
to be transported in the cabin of a
passenser-carrying aircraft under special
conditions.
9835
Authorizes a one-time shipment of hazardous
4
materials that are not specifically identified.
9844
Authorizes use of a non-DOT specification
2
folyethylene container of 15-gallon caracity,
similar to a DOT Specification 34, for shipment of
hydrosen peroxide, 60%.
9845
Authorizes transport of sulfuric acid; sulfuric
1
acid, spent or oleum in B DOT Seecification
111A100W2 or 103AW tank car tank with 3 modified
periodic tank relest interval.
9850
Authorizes transport of ammunition for cannon with
5
explosive projectile aboard carso sircraft.
9851
Authorizes a one-time shipment of insulated dewars
4
containing liquid nitrosen to be transorted in the
cabin of 3 passenser-carrying aircraft under
special conditions.
9853
Authorizes a one-time shipment of five 55-gallon
4
capacity, DOT Specification 34 polyethylene drums
containing 50% hydrosen peroxide which is
forbidden for transportation by sir.
9854
Authorizes transport of rocket motors via hishway.
5
9855
Authorizes shipment of explosive projectiles,
4
Class A explosives; rocket motor and propellant
explosive, solids, Class R explosive, which are
forbidden for transportation by air 01 are in
Quantities greater than those prescribed for air
transportation.
9856
Authorizes use of non-specification packaging and
5
patient use of oxysen systems on board 2 passenger
ship.
9869
Authorizes use of insulated DOT Specification
5
MC-307 stainless steel carso tanks, for
transportation of certain Class B poison.
D-68
NUMBER
PURPOSE
REASON
9878
Authorizes shipment of a solid waste, classed as a
5
Class R poison, contained in approximately 300 DOT
Specification 55-gallon capacity 17C drums.
9879
Authorizes = one-time shipment of sulfur dioxide
4
for disposal in 3 non-DOT specification steel
portable tank.
9880
Authorizes manufacture, marking and sale of
5
non-DOT specification containers described as
hermetically sealed electron tube devices.
9881
Authorizes manufacture, marking and sale of
5
non-DOT specification, metal, sinsle trip, inside
conteiners.
9895
Authorizes a one time shipment by motor vehicle of
4
explosive in metal conteiners. overpacked in a
strong wooden box.
9896
Authorizes shipment of approжimately 100,000 hass
5
marked with the shipping description RQ Cartan,
ORM-E, NA 9099 instead of the description RQ
Hazerdous Ssubstance, solid, n.o.s., ORM-E, NA
9188 (Captan) which is required beins Janury 1,
1988.
9897
Authorizes a one-time shipment of hydrogen
4
chloride, refriserated liQuid in P: DOT
Specification 105A600W tank car tank loaded to
less than the minimum required filling densits.
$
D-69
APPENDIX E
MEMORANDUM OF UNDERSTANDING
between the
Federal Emergency Management Agency
and the
Department of Transportation
I.
Purpose
This Memorandum of Understanding (MOU) establishes 8 framework of
cooperation between the Federal Emergency Management Agency (FEMA) and the
Department of Transportation (DOT) to identify emergency preparedness roles
and responsibilities involving the transportation of hazardous materials and
to establish joint program efforts in planning and training; and information
development, dissemination, and exchange. This Memorandum of Understanding
is not intended to affect programs, activities and responsibilities of the
United States Coast Guard concerning hazardous materials.
II.
Backaround
A.
FEMA and DOT are both involved in the development of plans, training
programs, and informational materials used by State and local
governments and the private sector in preparing for emergencies
involving the transportation of hazardous materials. Although the
legislative authorities for both FEMA and DOT are well understood,
further clarification is considered appropriate to maximize effec-
tiveness.
B.
This MOU is a mutual effort on the part of FEMA and DOT to identify:
(a) specific areas of responsibilities for each agency;
(b) areas where special expertise can be extended to each agency to
support programs with common goals; and
(c) areas where coordinated and cooperative programs between FEMA
and DOT will result in cost savings through the effective and
efficient use of human and material resources.
C.
The extent to which cooperative and coordinated efforts are imple-
mented is contingent upon the resources available to each agency.
Accomplishments under the terms of this agreement will be determined
by the ability of the signatories to provide adequate funding for
the execution of this instrument.
D.
The agreements and the assignments of roles and responsibilities
within the context of this instrument are limited to the signator-
ies. No other roles, responsibilities, or agreements are implied
for any other department, agency or organization, public or private.
E-1
III. Authorities and Responsibilities
A.
In developing and implementing plans and programs for hazardous
materials emergency preparedness, FEMA operates under the following
authorities:
1. The Civil Defense Act of 1950, BS amended, (50 App. U.S.C.
Section 2251, et seq.), under which FEMA is responsible for the
necessary direction, coordination, and guidance regarding the
development and execution of, inter alia, emergency response
operation plans. The Act authorizes FEMA to provide technical
and financial assistance to the States for developing civil
defense programs for both wartime and peacetime emergency
preparedness activities (including response to natural and man-
made disasters).
2. The Fire Prevention and Control Act of 1974 (15 U.S.C.
Section 2201, et seq.), under which FEMA is authorized to
provide technical assistance to the States for development of
emergency preparedness programs, which may include education
and training related to fire prevention and control, including
fire hazards associated with hazardous materials.
3. The Disaster Relief Act of 1974 (42 U.S.C. Section 5121, et
seq.), under which FEMA provides assistance to States to
support the development of comprehensive disaster. preparedness
plans which include hazard reduction, avoidance, and mitiga-
tion, as well as training and required exercises, coordination
of Federal, State, and local preparedness programs, and other
related elements.
4. Title III of the Superfund Amendments and Reauthorization Act
(SARA) of 1986, popularly known as the Emergency Planning and
Community Right to Know Act of 1986, provides authority to FEMA
to make grants to the States for training to support programs
of State and local governments and university-sponsored
programs which are designed to improve emergency planning,
preparedness, mitigation, response, and recovery capabilities.
5. Executive Order 12580 (January 23, 1987), which delegates
authority to various Federal agencies such as FEMA for imple-
menting the Comprehensive Environmental Response, Compensation
and Liability Act, as amended, also sets forth the requirement
for developing the National Contingency Plan (NCP). The NCP
describes the responsibilities of the member agencies of the
National Response Team (NRT), of which FEMA and DOT are
members. The NRT members participate in the development and
implementation of procedures for the coordination of response
actions to releases of hazardous substances.
E-2
B.
In the prevention and mitigation of hazardous materials emergencies
resulting from transportation incidents, the Department of
Transportation/RSPA operates under the following authorities:
1. The Hazardous Materials Transportation Act (49 App. U.S.C.
Section 1801, et seq.), which provides the Secretary of
Transportation with a broad grant of authority to regulate "any
safety aspect of the transportation of hazardous materials
which [she] deems necessary or appropriate." This grant of
authority extends not only to the designation, packaging, and
transport of hazardous materials and the enforcement of
regulations applicable thereto, but also to emergency prepared-
ness and response for hazardous materials incidents occurring
in transportation.
2. 49 App. U.S.C. Section 1808(d) (2) which directs the Secretary
to "provide law enforcement and firefighting personnel of
communities, and other interested persons and government
officers, with technical and other information and advice for
meeting emergencies connected with the transportation of
hazardous materials."
C. Specifically, FEMA responsibilities related to hazardous materials
emergency management preparedness, planning and training are:
1. To deliver training on hazardous materials emergency manage-
ment, planning, mitigation, and response to State and local
personnel.
2. To prepare, develop and disseminate training-related technical
assistance materials to State and local governments, and to the
private sector.
3. To prepare, develop and disseminate planning and preparedness-
related technical assistance materials to State and local
governments, and to the private sector.
4. To administer grants for State and local training programs and
university-sponsored training programs which are designed to
improve emergency planning, preparedness, mitigation, response,
and recóvery capabilities.
5. To provide 8 conduit for funding programs designed to improve
the capability of State and local governments to effectively
plan for the prevention, preparedness, and mitigation of
emergencies from hazardous materials incidents.
6. To develop, schedule, and conduct exercises to evaluate the
effectiveness of existing emergency management projects and
programs to the extent resources are available and to the
extent that they are required under existing FEMA programs.
E- 3
D.
Specifically, the responsibilities of the Department of Transporta-
tion related to the prevention and mitigation of accidents involving
the transportation of hazardous materials are:
1. To develop, promulgate and enforce regulations that are
necessary in support of emergency response activities involving
the transportation of hazardous materials.
2. To be the focus for State and local involvement in the enforce-
ment of regulations designed to provide for the safe transpor-
tation of hazardous materials.
3. To develop transportation-related training materials for
enforcement personnel of State and local governments.
4. To provide technical support and develop transportation
enforcement components of exercises designed for evaluating the
effectiveness of hazardous materials emergency response
programs.
5. To develop transportation-related technical assistance mater-
ials for use by State and local governments and the private
sector in hazardous materials emergency management programs.
6. To serve as a conduit for the delivery of technical assistance
to the law enforcement community in meeting their responsibili-
ties as the first on scene at transportation accidents involv-
ing hazardous materials.
IV.
Areas of Cooperation
The Department of Transportation and the Federal Emergency Management Agency
are committed to:
A.
Cooperate in the development and implementation of program initia-
tives, and integrate the planning and preparedness functions of FEMA
with the prevention and mitigation functions of DOT related to
emergencies involving the transportation of hazardous materials.
B.
Develop 8 two-year plan that encompasses the areas of cooperation,
to include joint projects and programs for training and technical
assistance.
C.
Review the work plan on an annual basis through 8 FEMA/DOT work
group and make appropriate adjustments.
D.
Conduct management meetings (through representatives appointed by
the Director and the Administrator) on a quarterly basis (or more
often) to review the status of joint programs, to discuss and
resolve issues, and to consult on major policy issues.
E- 4
E.
Develop hazardous materials training objectives of mutual interest
for the two year plan, and include the recommended resources
necessary to achieve these objectives.
F.
Coordinate the activities of this memorandum with the National
Response Team.
G.
Promote and support private sector initiatives that are beneficial
to the State and local government agencies responsible for prepared-
ness, prevention and mitioation of incidents involving the trans-
portation of hazardous materials.
H.
Provide funds to the extent available and practicable to support the
respective agency responsibilities under this Memorandum of Under-
standing.
V.
Effect
A.
This Memorandum of Understanding does not change, modify or limit in
any way the statutory authority or jurisdiction of either Agency.
B.
Nothing in this Memorandum of Understanding modifies other existing
agreements, or precludes either Agency from entering into separate
agreements setting forth procedures for special programs which can
be handled more efficiently and expeditiously by such special
agreement.
C.
This Memorandum of Understanding, when accepted by both Agencies,
shall continue in effect unless modified by mutual written consent
of both Agencies or terminated by either Agency upon a thirty-day
written notice.
D.
Any conflict arising out of this Memorandum of Understanding will be
resolved by FEMA's Associate Director for State and Local Programs
and Support and DOT's Administrator of the Research and Special
Programs Administration.
E-5
For the Federal Emergency Management Agency
Approved:
Julius W. Becton, Jr.
Director
Date:
For the Department of Transportation
Approved:
Eigabeth Elizabeth Hanford H. Dole Dole
Secretary
Date: April 23, 1987
.
E- 6