The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a May 22nd letter a question regarding emergency shutoff markings on cargo tanks.

PHMSA was responding to a March 21st email from Thatcher Transportation, Inc. (“Thatcher”).

Thatcher stated that it received a violation for an emergency shutoff marking not being close enough to the emergency closure device. § 172.328(d) of the Hazardous Materials Regulations (“HRM”) specifies that the emergency shutoff marking must be immediately adjacent to the emergency closure device. Included in Thatcher’s March 21st email was a photo showing the marking approximately 4 inches to the right of and 12 inches above the device.

Thatcher asked how close the emergency shutoff marking must be to the emergency closure device in order to meet the requirements of § 172.328(d). PHMSA responded that § 172.328(d) does not specify the distance the emergency shutoff marking must be in order to be immediately adjacent to the emergency closure device. Nevertheless, the agency stated:

. . . based on the description you provided in your email and the attached photo, it is the opinion of this Office that the emergency shutoff marking, as pictured, would be considered adjacent to the emergency closure device.

A copy of the PHMSA letter and the referenced photo can be downloaded here.