Document e5GyO7jjkZdrbQGw9navXZwyg

Et h y l Ga s o l i n e CO: Mr. W. Y. B lam ing, D irecto r Bureau of Motor C arriers I n te r s ta te Commerce Commission Co r po r a t i o n Washington, D.C. A ttn: Mr. H. H. A llen M .ANPACTUKING AND T H A I C D E P A H T M E N T J. H. SCH A EFER, MGR. A. P. ST OVER, ASST. MGR. E. J. GRESSLI N , TRAFFI C MGR. M AIL A D D R E S S : BOX 1271, W IL M IN G TO N . D EL. F R E IG H T A D D R E S S : C A R N E Y 'S P O IN T . N . J . TELEPH O N E: PEN N SG R O V E, N. J. 2 8 0 EXTENSION OSO February 16, 1958 Mr. lit. ? , B a rte l, S ecretary I n te r s ta te Commerce Commission Washington, D. 0 . Dear S ir: We have received a copy o f the second d r a f t o f Proposed Motor C arrie r S afety R egulations, P a rt 71 - T ran sp o rtatio n o f Explosives and Other Dangerous A rtic le s . A fte r c arefu l stu d y , is# welcome t h i s opportunity to o f f e r our comments, in accordance with your in v ita tio n o f January 25, Reference S. Generally speaking, i t is our opinion tlfa i'd ra ftin g and enforcement o f safety reg u la tio n s f o r the tra n sp o rta tio n o f explosivesNsmd o th er dangerous a rtic le s is a step in the rig h t direction. Ethyl baseline Corporation is fu lly ap p reciativ e o f the possible hazards? Ijeoshicb th e public a t la rg e could be exposed, should unsafe conditions o f transpobtktkon be p e rm itted . T herefore, tre should lik e to go on record as approving e n tir e ly th e p resen t movement o f the I n t e r s t a te Commerce Commission in ita-$tsm pt 'to^'fprm ulste a se t o f s a tis fa c to ry re g u la tio n s governing the tra n s p o rt^ tio n vo.f explosives and o th e r dangerous a r t i c l e s on the highways. Approval o f t h i s k*oVe^eplKis given with f u l l knowledge th a t our own commodity, "Motor Fuel Aati-Wnock'xCospbuAd,* i s a Class B poison, and i s s p e c if ic a lly mentioned in S e ctio n G. In order to a c q u a i n t m e t h o d s o f shipments of Motor Fuel Anti Shock Compounds by motor earribs^ likke th e follow ing c la s s if ic a tio n : 1 - In s te e l I0C-5 drums, 55-gailon and 10-gallon siz e s, normally v ia c o n tra ct and common c a r r ie r s . 2 - In s te e l tank tru ck s, 9S2-gallon normal capacity, by our owned t r a c t o r - t r a i l e r u n its . .-'. Alst Before commenting on se v era l se c tio n s o f t h i s second d ra ft with which we a re p a r tic u la r ly concerned, we should lik e to p o in t out th a t we now enforce r ig id safety p ra c tic e s , both in the handling and tran sp o rta tio n o f our product, a s a r e s u lt we wish to cooperate f u lly w ith t h i s worthwhile sa fe ty program. The follow ing suggestions a re subm itted, however, a s our comments. Page 5 - Paragraph 5-A (a ); This paragraph forbids acceptance by motor c a rrie r fo r tran sp o rta tio n , of packages containing dangerous a r t i c l e s which are in a leaking condition. This 'unquestionably covers acceptance a t p o in t o f o rig in o f shipment, but does not pro vide fo r emergency handling o f packages found leak in g enroute which may o f n e c e ssity have to be handled by a c a r r i e r fo r re tu rn to p o in t o f o rig in fo r proper and safe s d is p o s itio n . Tie suggest th a t t h i s paragraph be amended to include p rovisio n fo r emergency eases. , k e 00 00935 Mr. W. P, B a rte l February i s , 1938 Page 9 - Paragraph 10-A: ' No motor v eh icle tra n sp o rtin g any explosive o r o th e r dangerous a r t i c l e s h a ll he l e f t unattended except in grave emergency.......... 1 request th a t p er m ission b granted fo r garaging a cargo tank loaded with Motor Fuel M ti-Khock Compound. -while anro u te from the p la n t to consignee. During t h is period o f garag ing, i t is conceivable th a t th e tank tru c k would be l e f t unattended, and we see no o b jectio n to t h i s procedure, if suggest, th e re fo re , th a t th is reg u latio n should apply to motor v e h ic le s only while they ere on the p u b lic highway Pag 108 - Paragraph,,1-0 (b) - XV; This paragraph d e als with th e types o f containers In which i t is perm iss ib le to ship Motor Fuel Anti-Knock Compound, a l l o f which we are fa m ilia r with and e n tir e ly in accord. Mention i s made o f the use o f cargo tanks complying with an I.C .C . S p e c ific a tio n Number y et to be determ ined. In t h i s connection, we request perm ission to bp a p a rty to the discussion determ ining th is sp e c ific a tio n number, provided, o f course, th a t such a req u est can be granted. Page 118 - Paragraph 7-G ; This se c tio n would req u ire e l l motor v eh icles tra n sp o rtin g poisonous liq u id s , Glass B, to bs marked by the word ''POISONOUS," in whit l e t t e r s not le s s than th re e inches high-:&sd .on...a Hed background, on each sid e and on the re a r o f the vehicle. I t i s our fe e lin g th a t th is a p p lic a tio n would not c o n trib u te to the safe handling of a poisonous product as w ell as a placard containing a set of safety reg u latio n s end in stru c tio n s for handling. This placard to be placed inside of d r iv e r 's cab, fo r example, f o r the use o f the d riv e r who i s th e p a rty d ire c tly concerned w ith the handling of emergencies in connection with the cargo carried. Our d riv e rs sad s l l employees a t our customers* i n s ta lla tio n s , are governed by a d e fin ite s e t o f s a fe ty re g u la tio n s and a re f u l ly in s tru c te d as to the dangers o f handling ths commodity. Because o f th e p o ss ib le pu b lic a s s o c ia tio n o f ETHYL F luid w ith Ethyl G asoline, I t seems apparent th a t th e re would be a psychological e ffe c t upon th e p u b lic so a s to have an adverse Influence upon the sa le o f Ethyl G asoline. In view o f t h i s and our s t r i c t re g u la tio n s f o r the handling of our commodity, we req u est th a t our product be exempted from th e requirem ents governing th e display o f the sign "POISONOUS," fo r th e reasons ju s t enumerated. We might add th a t our tank tru ck s a re placarded by h arin g an enamelled sig n approximately 15" x 24" displayed oa each side of ths t r a i l e r , bearing the following warning: WASHING .CONTAINS TETRAETHYL LEAD: CONTENTS POISONOUS. IN EVENT OF DAMAGE TO TANK KEEP/WAY DO NOT BREATHS FUMES NOB ALLOW CONTACT WMH SKIN OB CLOTHING. SHOULD ANY OF THIS FLUID GET ON BODY OS CLOTHES IT SHOULD BE REMOVED IMMEDIATELY BY WASHING THOROUGHLY WITH GASOLINE OR KEROSENE FOLLOWED BY SOAP AND WATER. NOTIFY BY IRE, CHARGES COLLECT ETHYL GASOLINE CORPORATION, WIDIINGT0N, DELAWARE. He 0000936 -3- Hr, W. ? . Bartel February 18, 1938 Page 181 * Paragraph 13-G: ' We believe th a t th ia paragraph should be made applicable to explosives only. S tric t compliance with th is regulation would, as we in terp ret i t , make i t p ractica lly impossible to effeot delivery. We suggest that th is be modified to permit parking that would allow purchases of food, and gasoline, and for other purposes fa llin g under the classific atio n of normal operation. JB3-- We ars opposed to the provision that cargo tanks used fo r the transpor ta tio n of Motor Fuel Anti-Knock Compound sh a ll be painted a bright lied color, as set fo rth in the regulations in Paragraph 22-C fo r inflammable liq u id s. Motor Fuel .nti-Snook Compound is made in various colors, including Red. This is a requirement of the Baited States Public Health Department. Minimum dye concentratlons have been adopted fo r the specific purpose of assuring su fficien t staining quality to show immediate evidence of leakage. This sta in -, ing feature can only be assured by the use of a neutral color paint, such as Gray, vhlqh w ill act as a suitable background fo r discoloration through leakage, For th is reason we request th at the use of Gray paint for motor vehicles transporting Motor Biel Anti-Shock Compound bo approved to allow us to conform with the regula tio n s o f the United States Surgeon General. * Under present regulations, Red used as the color for placards and labels is indicative of an inflammable or an explosive m aterial, We feel th at the use of Red paint for our cargo teaks would be misleading as to the nature of our product, and that the broader use of Rod as applied to the color of cargo tanks would tend to lessen the effectiveness of Bed as a warning and indication of explosives and other more dangerous a rtic le s . _ Will you please keep us advised es to the time and place hearing w ill bo held for consideration of these proposed regulations. Respectfully yours, STHYL BASQUES CORPORATION J . H. Schaefer BiNF J Kf 0000937