PHMSA letter of interpretation

Propane Shipping Names and Identification Numbers

Pipeline and Hazardous Materials Safety Administration · Oct 1, 1995 · Reference No. 95-0100

PHMSA says to use caution with this letter. On January 21st, 2016, PHMSA published Final Rule, HM-233F, which incorporated Special Permit 13544 by adding Special Provision N95 to allow for the transportation of cylinders containing UN1075 and UN1978 without marks and labels under certain conditions.

Interprets: 49 CFR § 171.102, 49 CFR § 172.202, 49 CFR § 172.336

This is in response to your April 25, 1995 letter and subsequent telephone conversation with a member of my staff concerning the interchangeability of proper shipping name and identification (I.D.) number on shipping papers and markings for cargo tanks containing propane. You presented eight scenarios and asked five questions. The questions are paraphrased and answered as follows.

Q1. Is "Propane" an appropriate common name for "Petroleum Gases, Liquefied" and vice versa?

A1. "Petroleum gases, liquefied" may be used as a common name for various liquefied petroleum gases, including propane. "Propane" is an authorized alternate shipping name for "Petroleum gases, liquefied" and may be used as a common name for "Petroleum gases, liquefied" if the packaging contains only propane and no other liquefied petroleum gas.

Q2. Does the exception in 49 CFR 172.336(c)(5) apply to any of the scenarios?

A2. No. This exception applies to liquid petroleum distillate fuels. Liquefied petroleum gas and Propane are liquefied compressed gases. See § 173.115(e).

Q3. What is the regulatory definition of "liquid petroleum distillate fuel" and where can it be found?

A3. "Liquid petroleum distillate fuel" is not specifically defined in the Hazardous Materials Regulations. In general terms, a liquid petroleum distillate fuel is a liquid mixture of hydrocarbons extracted from petroleum by distillation and is used in many applications, including fuel.

Q4. Is there a listing of "liquid petroleum distillate fuels" along with their associated flash points? If so, where is it found?

A4. This Office does not maintain a list of liquid petroleum distillate fuels.

Q5. Are there any violations in each of the scenarios listed? If so, what are the referenced regulations for those violations?

A5. Scenario 1: Correct

Scenario 2: The I.D. number "1978" must be consistent on shipping papers and package markings.

Scenario 3: The I.D. number shown on the shipping paper should be "1075".

Scenario 4: The I.D. number shown on the shipping paper and marked on the package should be "1075".

Scenario 5: Correct.

Scenario 6: The I.D. number marked on the package should be "1075".

Scenario 7: The I.D. number marked on the package should be "1075".

Scenario 8: Correct.

If a common name is used rather than the proper shipping name for marking a cargo tank (see § 172.328), the I.D. number marked on the cargo tank must match the I.D. number shown on the shipping papers, regardless of whether the common name is listed in the § 172.101 Table with a different I.D. number. Special Provision 19, referenced in Column (7) of the § 172.101 Table for "Propane" and other specific liquefied petroleum gases, permits use of the I.D. number "UN1075" for domestic transportation only. The I.D. number must be consistent on shipping papers, package markings and emergency response information.

The intended effect of Special Provision 19 is to allow cargo tanks and tank cars used to carry various types of liquefied petroleum gases to be marked with one I.D. number (1075). It is this Office's opinion that if a shipper uses "Propane" as the proper shipping name on shipping papers and "Petroleum gases, liquefied" as the common name on package markings, the I.D. number shown on shipping papers and marked on packages should be "1075".

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.