Document MGOB0RvrB3z2gnqDKmY7y552L

TO: Tom Randolph JJH: JCL: TGG; RF XF:__ -____________ Interoffice Communication FROM: DATE: SUBJ: Tom Grumbles April 15, 1985 DOT HAZ MAT QUESTIONS VIS17 Probably much to your surprise I'm going to answer some of the questions youTve come up with over the past months. These answers are generally based on talking to others in the business. 1. Empty vendor or common carrier trailers - It is clear that "empty packagings" must have shipping papers which may contain the empty designation. (172:203(e)) What is not clear is who the shipper is at the point of leaving the plant. The refinery citations frould seem to indicate that the customer would be considered "shipper" for empty returns. I would propose that we establish a procedure to assure that the driver has shipping papers for the return trip. If he doesn't we should consider supplying some form of papers. Call if you want to discuss this. 2. Should we require drivers to assure us they have secured empty trailers? If we have any type of post-load or post-delivery procedure, checking that all necessary valves are closed should be a part of it. If we don't have procedures then this type of inspection should probably be done "at the gate". A signed statement would of course add to our defense if a similar occurrence to the refinery Dimethyl Sulfide trailers occurred. 3. Is the destination required on HAZ MAT Bills of Lading? As we thought, the destination is not legally required on the shipping papers. 4. What is the placarding requirement for compartmentalized trucks with hazardous and non-hazardous loads? Regardless of the mixture of hazardous and non-hazardous materials, placards must be placed on both sides and both ends. There are exceptions for the display of HI numbers on the ends of such containers (172.336), but not placards. These items are, of course, subject to second guessing. Please call if you want to discuss. cc: B. Tuzinkiewicz VVV 000015778