b'Marketer Member NewsRules & RegulationscontinuedHow to Correctly Placard Cargo Tank Vehicles to the Lowest Flash Point for Mixed Loads of Gasoline and Diesel FuelWashington, D.C. - EMA is continuing PLACARDING FOR STRAIGHT LOADSto hear from marketers whose cargo tankStraight load shipments are those that contain the same product in vehicles are being ticketed and placedall compartments of the same cargo tank vehicle. Straight loads out of service for incorrect placarding ofof gasoline must be marked with the cargo tank placard iden-alternating strait loads of diesel fuel withtification number UN1203 or GASOLINE. Straight loads the UN1203 placard. Historically, theof diesel fuel may be marked with either the cargo tank placard U.S. DOTs Pipeline and Hazardous identification number NA1993 or UN1202. If there is no Materials Safety Administration (PHMSA)gasoline in a compartment of a cargo tank, then the UN1203 allowed the use of the UN1203 placardplacard cannot be used for straight loads of diesel fuel.Mark S. Morgan, Esqfor both split loads of gasoline and diesel EMA Regulatory fuel as well as for alternating straight Counsel loads of gasoline and diesel fuel. ThisPLACARDING FOR SPLIT LOADSpractice relieved drivers from continuallySplit load shipments are those that contain different products in changing placard between loads of gaso- separate compartments of the same cargo tank vehicle. If gaso-line and diesel fuel. The interchangeabil- line and diesel fuel are shipped in separate compartments of the ity of the UN1203 placard for gasolinesame cargo tank shipment, then the placard for the product with with the NA1993 and UN1202 placardsthe lowest flashpoint must be used. In the case of gasoline and for diesel fuel makes sense becausediesel fuel shipped together in a cargo tank, the placard must read emergency responders employ identicaleither UN1203 or GASOLINE.containment and firefighting techniques for both. Marketers placarded the cargoPHMSA CLARIFICATIONStank vehicles in this way for years with-out problem, until now.Although shipments of gasoline and diesel fuel in a cargoIn 2013, PHMSA issued an interpretive letter that stood this tank vehicle must be placarded, either the UN1203 or placarding practice on its head, causing ongoing confusionGASOLINE placard may be used. among marketers and roadside enforcement personnel alike.PHMSA only allows placarding to the lowest flashpoint ofIn the interpretive letter, PHMSA continued to allow placardingthe product in any compartment of a split load. There can be to the lowest flashpoint anytime both gasoline and diesel wereno placarding to the lowest flashpoint when all compartments shipped simultaneously in different compartments of the samecontain the same product.cargo tank vehicle. However, placarding to the lowest flashpoint PHMSA no longer allows straight loads of diesel fuel to be for alternating straight loads of gasoline and diesel fuel would no longer be allowed. PHMSAs reasoning for eliminating theplacarded with UN1203 or GASOLINE placards. If there placarding exception for alternating straight loads of gasoline is no gasoline in the shipment, then the UN1203 placard may and diesel fuel was simple, the agencys regulations never not be used. Instead, only the NA1993 or UN1202 placards allowed it in the first place. may be used only for straight loads of diesel fuel shipments.Although the interpretive letter is now ten years old, many mar- In the case where a cargo tank vehicle has one empty compart-keters are not aware of the regulatory changes it contains. Thesement that previously held gasoline while the remaining compart-marketers are at risk for hefty monetary penalties and out of ser- ments all contain diesel fuel, the UN 1203 or GASOLINE vice orders. In order to mitigate these risks, marketers should readplacard must be used if the empty compartment was not cleaned and understand the following placarding clarifications issued byof product and purged of vapors. The reason for this is that PHMSA before they are subject to the next roadside inspection. PHMSA treats an empty compartment not cleaned and purged as though it holds the product it previously contained for compli-ance purposes. 42www.wpma.com / Post WPMAEXPO'