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Wrong Placard

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Wrong Placard
Posted by ericsp on Thursday, May 7, 2009 11:14 PM

I saw two 33,000 gallon, pressure tankcars stenciled for gasoline (placard number 1203) but placarded 1268 (petroleum distillates, not otherwise specified). 

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Posted by edbenton on Friday, May 8, 2009 7:26 AM

They could have been carrying so called Ruined gasoline.  AKA gas mixed with water from a fuel spill or a fuel tank removal.  1268 is the placard code for any Petroluim Distallate aka gas mixed with water when they remove it from a underground fuel tank if it is contaminaed with something.  It was more than likely being shipped to a Cement plant to be burned as fuel heck those plants can burn just about anything up to discarded tires. that tell you how HOT they get.

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Posted by CShaveRR on Friday, May 8, 2009 8:28 AM
Eric, I also show 1268 as "Petroleum Products, n.o.s." That would cover a multitude of commodities, some pretty much akin to gasoline. I've seen a number of former LPG tank cars converted for the transportation of "Pyrolysis Gasoline", which may or may not be different from ordinary gasoline in the eyes of the placarder.

Carl

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Posted by Paul_D_North_Jr on Friday, May 8, 2009 8:56 AM

Couple questions from someone with zilch experience and not much knowledge about this, as you'll see: 

Was the 1203 stencilled on the cars ?  I presume not, though.

If not - and maybe even if it was - wouldn't the placard take precedence over the stencil ?  In other words, even if the car was painted / stencilled for baby powder Wink , if it has the 1268 placard everybody has to treat it like it has 1268 in it, right ?

Are there any negative implications of doing that - putting a placard on a car that is stencilled for something else ?  From a Haz-Mat compliance and safety perspective, how else do you put an oddball commodity into whatever car shows up for you to load, if it is otherwise of the proper type ?

Separate question is properly notifying the carrier for billing purposes - the actual commodity may have a different rate than the stencilled commodity.

Ed, that's a good catch, and likely the case - something from experience, and not likely in the standard textbooks, I suspect.  My daughter is in that line of work (also HAZWOPER certified), and has some experience in filling out the RCRA "cradle-to-grave" shipping documents and tracking same.  I'll have to ask her about that sometime.

You're also quite right about the cement plants.  LaFarge in Whitehall here specializes in burning tires and oddball recycled plastics (the ones that are not /1\ or /2\ -- i.e., the /3\ through /7\ groups, and the ones without numbers); Keystone over in Bath specializes in burning liquid hazardous wastes of various kinds (waste oil, etc.).  I'm not sure what Hercules or Essroc in Nazareth burn, or Lehigh-Heidelburg in Evansville.  They assure - and the DEP tests to support it - that there is essentially total destruction of the complex molecules at those temperatures - I believe it, too.  Handy things to have around, if you ever really want to get rid of the stuff, instead of just moving it around or literally covering it up (which is all a lot of so-called "environmental clean-ups" are otherwise).

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Posted by Paul_D_North_Jr on Friday, May 8, 2009 8:59 AM

Carl - what does the "n.o.s." stand for ?  "Not Otherwise Specified" ?

Back in the day, I knew that "NOIBN" for freight rates = "Not Otherwise Indexed By Name" - is that similar ?

Thanks !

- PDN.

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Posted by CShaveRR on Friday, May 8, 2009 9:33 AM
Yes, and yes.

Carl

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Posted by Deggesty on Friday, May 8, 2009 12:29 PM

In response to several questions/statements by PDN:

"If not - and maybe even if it was - wouldn't the placard take precedence over the stencil ? In other words, even if the car was painted / stencilled for baby powder , if it has the 1268 placard everybody has to treat it like it has 1268 in it, right ?" "Are there any negative implications of doing that - putting a placard on a car that is stencilled for something else ? From a Haz-Mat compliance and safety perspective, how else do you put an oddball commodity into whatever car shows up for you to load, if it is otherwise of the proper type ?"

IIRC, I had to be careful about what was on the package and make certain that any description on the package matched the label (and placard) when I was shipping dangerous goods. You may remember a thread a while back which went into the proper placard for gasoline, and it seemed that several different numbers could be used.

 

"My daughter is in that line of work (also HAZWOPER certified), and has some experience in filling out the RCRA "cradle-to-grave" shipping documents and tracking same. "

I’m glad that I never had to worry with "cradle to grave," though I had some instruction in that in my in-house required classes in handling dangerous substances.

 

"Carl - what does the "n.o.s." stand for ? "Not Otherwise Specified" ?"

Just think how many numbers would be required if "n.o.s." were not allowed. It certainly can cover a number of equally evil substances. And the same goes for "NOIBN." (though not necessarily evil items). There were times when I had to check the classification for truck freight rates, and there were items we shipped that were not listed, and had to be in a catch-all class.

I enjoyed the work (much of it was independent), but I do not really miss it.

Johnny

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Posted by Randy Stahl on Friday, May 8, 2009 12:53 PM

More importantly is the hazard class . N.O.S can be in many different classes. Class is more imprtant than the actual substance.

The other important thing is that the placard match the waybill , a good example is 1993 (combustable) Diesel fuel oil and 1203 (flammable) Both are diesel fuel but one has a higher flashpoint than the other.

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Posted by ericsp on Friday, May 8, 2009 10:26 PM

There was not a 1203 anywhere on the car. I am assuming that if the stencil (if there is any) and the placard are not for the same thing, then the more hazardous of the two would be assumed. About a decade ago, I saw two 33,000 pressure tankcars placarded for gasoline but stenciled for LPG. In that case one would assume the stencil was correct. If the placard as 1075 and the stencil was gasoline, I would assume that the placard would be assumed to be correct.

Carl, we get LPG type cars hauling other commodities out here also. The most common are liquid hydrocarbon, n.o.s. (3295) and pentane. I have seen a MSDS for natural gasoline that has 3295 for the placard number. However, I have seen more that have 1203. Gasoline is not uncommon.

It appears that pyrolysis gasoline can vary in its composition and placard number. There is no listing in the ERG for it. I have found material data safety sheets listing its placard number as 1202, 1203, and 1993.

According to the listing for gasoline in the ERG, its only number is 1203.

I suppose that the tankcars I saw could have had their commodities changed and the stencil not painted over; which would make the stencil wrong. 

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