PHMSA letter of interpretation

Hyphen in Emergency Shutoff marking

Pipeline and Hazardous Materials Safety Administration · Dec 20, 2024 · Reference No. 24-0100

Interprets: 49 CFR § 172.328(d)

December 20, 2024

Reference No. 24-0100

This letter is in response to your October 19, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to markings on cargo tanks. Specifically, you ask whether the “Emergency Shutoff” marking requirement provided in § 172.328(d) permits the use of a hyphen in the word shutoff as follows: “SHUT-OFF”. In a follow-up email, you also provided a picture of the scenario you described.

The answer is yes. Although the required text of “Emergency Shutoff” provided in § 172.328(d) does not include a hyphen in the word shutoff, it is the opinion of this Office that ing a hyphen as described is not contrary to the intent of the requirement and does not cause confusion, , or diminish the meaning or effectiveness of the marking.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.328(d)

A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.