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Pamphlet 76

Guidelines for the Safe


Motor Vehicular
Transportation of Chlorine
Cylinders and Ton
Containers

Edition 5

June 2012
Table of Contents
1. INTRODUCTION........................................................................................................................ 1
1.1 Scope .................................................................................................................................. 1
1.2 Chlorine Institute Stewardship Program ............................................................................. 1
1.3 Definitions ........................................................................................................................... 1
1.4 Disclaimer ........................................................................................................................... 2
1.5 Approval .............................................................................................................................. 2
1.6 Revisions ............................................................................................................................. 2
1.7 Reproduction ....................................................................................................................... 2

2. TRANSPORTING 100 AND 150 LB CYLINDERS ................................................................... 2


2.1 Closed Van Trucks/Box Trailers ......................................................................................... 2
2.2 Open Top - Trucks/Trailers ................................................................................................. 7
2.3 Construction ........................................................................................................................ 7
2.4 Cylinder Loading and Unloading ......................................................................................... 8

3. TRANSPORTING TON CONTAINERS ..................................................................................... 9


3.1 Open Top Trucks and Trailers ............................................................................................ 9
3.2 Ton Container Loading and Unloading ............................................................................. 13
3.3 Double Stacking Ton Containers ...................................................................................... 13

4. COMBINATION SHIPMENTS ................................................................................................. 14


4.1 Cylinder and Ton Containers ............................................................................................ 14
4.2 Chlorine and Other Chemical Shipments ......................................................................... 14

5. PRIVATE AND COMMON CARRIERS ................................................................................... 15


5.1 Common Carriers .............................................................................................................. 15
5.2 Hazardous Materials Safety Permit .................................................................................. 15
5.3 Security Plan ..................................................................................................................... 15
5.4 Security Awareness Training ............................................................................................ 16
5.5 PHMSA Registration ......................................................................................................... 16
5.6 Shipping Papers ................................................................................................................ 16
5.7 Preventative Maintenance Program ................................................................................. 16
5.8 Personal Protective Equipment ........................................................................................ 16

6. EMERGENCY RESPONSE ..................................................................................................... 16


6.1 CHLOREP ......................................................................................................................... 16
6.2 CHEMTREC and CANUTEC ............................................................................................ 17
6.3 Personal Protectective Equipment.................................................................................... 17
6.4 Reporting of Release ........................................................................................................ 17
6.5 Emergency Kits ................................................................................................................. 18

7. TRAINING .............................................................................................................................. 18

i
7.1 General.............................................................................................................................. 18
7.2 Mandatory Training Requirements ................................................................................... 19

8. REGULATIONS ....................................................................................................................... 19
8.1 DOT Regulations .............................................................................................................. 19
8.2 TSA Recommendations .................................................................................................... 20
8.3 Canadian Regulations....................................................................................................... 20
8.4 Other Regulations ............................................................................................................. 20

9. REFERENCES ........................................................................................................................ 21
9.1 Chlorine Institute References ........................................................................................... 21
9.2 DOT Regulations .............................................................................................................. 22
9.3 TSA Recommendations .................................................................................................... 22
9.4 Transport Canada Regulations ......................................................................................... 22
9.5 Other Chlorine Institute Publications ................................................................................ 23

APPENDIX A - CHECKLIST ........................................................................................................ 25

ii
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 1

1. INTRODUCTION

1.1 SCOPE

The motor vehicular transportation of chlorine is extensively regulated by the U.S.


Department of Transportation (DOT) and Transport Canada (TC). This pamphlet is not
meant as a summary or substitute for those regulations. All persons transporting chlorine or
offering chlorine for transportation should be thoroughly familiar with all applicable
regulations.

1.2 CHLORINE INSTITUTE STEWARDSHIP PROGRAM

The Chlorine Institute (CI) exists to support the chlor-alkali industry and serve the public by
fostering continuous improvements to safety and the protection of human health and the
environment connected with the production, distribution and use of chlorine, sodium and
potassium hydroxides, and sodium hypochlorite; and the distribution and use of hydrogen
chloride. This support extends to giving continued attention to the security of chlorine
handling operations.

Chlorine Institute members are committed to adopting CIs safety and stewardship initiatives,
including pamphlets, checklists, and incident sharing, that will assist members in achieving
measurable improvement. For more information on the Institutes stewardship program, visit
CIs website at www.chlorineinstitute.org.

1.3 DEFINITIONS AND ACRONYMS

In this pamphlet the following meanings apply unless otherwise noted:

CFR Code of Federal Regulations

DOT U.S. Department of Transportation

EPA U.S. Environmental Protection Agency

Institute The Chlorine Institute

FIFRA Federal Insecticide, Fungicide, Rodenticide Act

FMCSA Federal Motor Carrier Safety Administration

RCRA Resource Conservation Recovery Act

TC Transport Canada

TSA Transportation Security Administration


2 PAMPHLET 76

1.4 DISCLAIMER

The information in this pamphlet is drawn from sources believed to be reliable. The Institute
and its members, jointly and severally, make no guarantee and assume no liability in
connection with any of this information. Moreover, it should not be assumed that every
acceptable procedure is included or that special circumstances may not warrant modified or
an additional procedure. The user should be aware that changing technology or regulations
may require a change in the recommendations herein. Appropriate steps should be taken to
insure that the information is current when used. These recommendations should not be
confused with federal, state, provincial, municipal or insurance requirements, or with national
safety codes.

1.5 APPROVAL

The Institute's Transportation Issue Team approved Edition 5 of this pamphlet on June 4,
2012.

1.6 REVISIONS

Suggestions for revisions should be directed to the Secretary of the Institute.

1.6.1 Significant Revisions in Current Edition

Edition 5 of this pamphlet includes clarifications regarding securement and containment


(Sections 2 and 3) and container separation for combined shipments (Section 4), new
sections regarding preventative maintenance programs (Section 5.7), recommended
personal protective equipment (Section 5.8) and emergency response (Section 6) and
clarifications on relevant training requirements (Section 7) and federal regulations (Section
8).

1.7 REPRODUCTION

The contents of this pamphlet are not to be copied for publication, in whole or in part, without
prior Institute permission.

2. TRANSPORTING 100 AND 150 LB CYLINDERS

2.1 CLOSED VAN TRUCKS/BOX TRAILERS

Closed van trucks and box trailers are commonly used for shipping chlorine cylinders. When
transporting chlorine cylinders via closed van trucks or box trailers, it is recommended the
trailers have ventilation openings in the front and rear of the trailer. This creates a minimal
forced airflow through the trailer. No package marked poison, poison gas or poison
inhalation hazard may be loaded into a motor vehicle carrying any type of foodstuff (human
or animal), nor into the drivers compartment (including sleeper berth) of a motor vehicle (see
49 CFR 177.841) (9.2.1).
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 3

Modifying standard equipment to improve the safe transportation of chlorine cylinders is


recommended. Among these modifications are the following:

2.1.1 Decking

Diamond plate steel decks offer some advantages over wooden floors for truck or trailer
beds such as resistance to rotting, reducing the risk of fires, and reducing maintenance.
The floor thickness should be a minimum of 5/16 inch unless applied over original wooden
decks, in which case inch is considered acceptable. However, wood decking does not
present the slipping hazard that exists with wet steel decking. Typical specifications for
wood decking in van trucks or box trailers call for 11/8 inch laminated oak flooring laid over
structural steel cross-members. For open bodied trucks and flat-bed trailers, 13/4 inch oak
shiplap flooring is generally used.

2.1.2 Bulkhead Attachments

Steel rings can be used to anchor strapping and chains for securing the cylinder load. These
rings should be attached to the van truck or box trailer wall by bolting through the side walls
(Figure 2.1).

The rings should be located at two levels, approximately 15 inches and 36 inches, from the
floor. (If compressed gas cylinders with different heights are transported in the van truck or
box trailer, additional levels of rings may be required.)

Figure 2.1
Steel rings used for securing cylinders to van truck wall
4 PAMPHLET 76

2.1.3 Bulkhead Tracks

Logistic rail (wall track or E track) is widely used with patented fasteners as part of
containment systems for shipping chlorine cylinders. Rail at levels of approximately 15
inches and 36 inches off the truck bed floor should be installed and fastened to structural
members of the van truck or box trailer walls (Figure 2.2).

Figure 2.2
Straps and logistic rail for securing cylinders

2.1.4 Cylinder Containment in Vans and Box Trailers

Some suggested methods of containing chlorine cylinders in van trucks or box trailers
employ load bars (with a logistic rail system) or nylon strapping (with logistic rails or wall
rings) (Figures 2.1 and 2.2). The load bars are suggested when a load of cylinders consists
of a sufficient number to fill the van/box or a bay of the van/box (Figure 2.3).
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 5

Figure 2.3
Load bars and logistic rail for securing cylinders

Nylon straps can be used to augment this method. Patented systems using load bars are
available. The strength rating of the nylon strap binding should be at least one half the
weight of the aggregate product to be secured (49 CFR 393.106(d)) (9.2.1).

For example, if 10 chlorine cylinders are transported with an average weight of 250 lbs each
resulting in an aggregate weight of 2500 lbs, then the securement strap used should be
rated to at least 1250 lbs. Nylon straps with a 3000 lbs minimum test rating are commonly
used for containing nested clusters of chlorine cylinders along the van truck or box trailer
wall. If more than 10 cylinders are to be contained in a cluster, higher strength rated straps
should be used. The nylon strap binding should be applied at the 15" and 36" levels around
the cylinders. A ratchet buckle is one suggested method for tightening the straps. Care
must be taken if chains are used for containing chlorine cylinders in vans or closed trailers
since the binder often requires excessive force to close and release; strain can pull out the
wall rings or buckle the walls.

Nesting is a method of securing cylinders in a tight mass using a contiguous three-point


contact system where all cylinders in the group have at least three points of contact with
other cylinders, walls, or bracing. Nested cylinders have three contact points and are
considered to be more stable in this configuration. See Figure 2.4.
6 PAMPHLET 76

Cylinders Aligned, Nested Cylinders


but not Nested

Figure 2.4
Nested Versus Non-Nested Cylinders

Cylinders secured to pallets offer a safe, secure method of shipping chlorine cylinders if the
proper loading and unloading equipment (e.g. forklift trucks, loading docks, etc.) are
available at the shipping and delivery points. Special caged pallets, capable of holding 12 to
16 cylinders, normally constructed of metal can be used when the truck bed construction
allows. Reinforcement of the bed may be required to handle the loaded pallets. Provision
must be made for securing cylinders to cages that are partially full to prevent movement
while in transit. (See 49 CFR 393.100) (9.2.1).

When used in transportation, provisions must be made for securing the pallets to the truck or
trailer bed. A standard pallet size of 401/4 inches x 451/2 inches will hold 16 chlorine cylinders
(Figure 2.5).

Figure 2.5
Palletizing cylinders
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 7

2.2 OPEN TOP - TRUCKS/TRAILERS

Another frequently used method of transporting chlorine cylinders over the road is by stake
body trucks and trailers.

Figure 2.6
Chains used for securing cylinders in stake body trailers

2.3 CONSTRUCTION

The decking construction recommendations for these units are covered in Section 2.1.1.

In the absence of the van truck or box trailer walls, vertical stakes and horizontal crossbars
constructed of tubular steel must be used for the sides and ends. The 36 inch high vertical
stakes should be welded to the deck frame. Crossbars with end lock fittings and keyed
receptacles or pockets in the vertical stakes are positioned at heights of approximately 15
inches and 36 inches above the decking. These crossbars can be integrated with a logistic
rail (load bar) system. (If solid bulkheads are used in lieu of stakes, a minimum height of 42
inches is recommended.)

2.3.1 Cylinder Containment in Open Trucks/Trailers

The combination of load bars and chains with acceptable binders, are recommended for
securing chlorine cylinders in open bodied trucks or trailers (Figures 2.3 and 2.6). The
strength of load binders must be equal to or greater than the minimum strength specified for
the chains (49 CFR 393.102(b)) (9.2.1).

The recommendation in Section 2.1.4 with regard to nested cylinders and the use of pallets
also applies to open trucks and trailers. Secured containment racks can also be used.
8 PAMPHLET 76

2.4 CYLINDER LOADING AND UNLOADING

Trucks and trailers used for transporting chlorine cylinders should be equipped with electric
or hydraulic lift gates for loading and unloading to ground level, unless severe climate
conditions prevent reliable operation.

The selection of lift gates is based on preference and service with mounting either on the
side or rear of the trailer bed. However, it is important to observe the weight limitation of the
unit installed. A minimum capacity of 5000 lbs is recommended. Frequent maintenance
checks, with particular attention to lubrication of cables and safety stops, are essential for
safe operation. Climatic conditions should be considered when determining the frequency of
liftgate preventive maintenance service.

Provision must be made for side and rear guards on the tail gate platform while raising or
lowering cylinders. Removable railings or swing gates with cross members at 15 inch and
36 inch heights or custom guard rail systems offer the required protection (Figure 2.7).

Figure 2.7
Ground level loading & unloading cylinders

Hand trucks are recommended to move cylinders from the delivery truck to the storage area
unless other suitable equipment is available. Horizontal loading of cylinders is not
recommended because a valve leak when a cylinder is in the horizontal position may leak
liquid chlorine.
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 9

3. TRANSPORTING TON CONTAINERS

3.1 OPEN TOP TRUCKS AND TRAILERS

Although it is recognized that large quantities of chlorine in ton containers are transported in
closed van trucks and box trailers in North America (e.g. containerized export shipments),
most ton containers are moved over the road in open top trailers. On the occasion that ton
containers are transported by closed van trucks or box trailers, it is recommended the trailers
have ventilation openings in the front and rear. This creates a minimal forced airflow
through the trailer.

No package marked poison, poison gas, or poison inhalation hazard may be loaded into a
motor vehicle carrying any type of foodstuff (human or animal), nor into the drivers
compartment (including sleeper berth) of a motor vehicle (see 49 CFR 177.841) (9.2.1).

It is beyond the scope of this pamphlet to detail the requirements for the running gear, such
as tandem axles, computerized brakes, etc. The selection of equipment of this type is
dictated by federal, state, and provincial regulations. Note, care must be taken to secure
labels in open top vehicles. Likewise, the weight limitations may vary from state to state
while Canadian limits exceed those in the U.S.

3.1.1 Decking

Recommendations for floor decking are covered in Section 2.1.1. Specialized unloading
systems used on trailers dedicated to ton container transportation service, such as the
automatic unloading units, are built either with or without floor decking (See Section 3.1.3).

3.1.2 Containment of Ton Containers on Open Top Trucks and Trailers

Except for self-unloading trailers, the need to roll the containers to the rear of the trailer bed
prevents the use of fixed chocks or cradles for each container. The U.S. Department of
Transportation (DOT) regulates securement systems, including the number and strength of
chains needed to secure cylinders and ton containers in 49 CFR 393.102(d) (9.2.1). The
rule states that the working load limit of the tie-down assemblies used to secure an article in
any direction must be at least one half the weight of the aggregate product and containers.
Different sizes and numbers of chains are needed to secure various numbers and tare
weights of ton containers. Refer to the table in 49 CFR 393.108 for various working load
limits (9.2.1).

For the purpose of this pamphlet, the most typical or common methods of securing cylinders
and ton containers are described herein, although other methods may be used in industry.
Before establishing a securement method, it is crucial to verify compliance with DOT
regulations in 49 CFR 393 (9.2.1).
10 PAMPHLET 76

3.1.3 Inspection of Chains and Straps

It is recommended that each shipper develop a schedule to visually examine all chains and
straps used to secure chlorine containers and that the inspection is documented on the
drivers log to verify completion. The following items should be looked at:

wear bend
nicks throat size of hooks
cracks chains must move freely with adjacent
breaks links
gouges cuts
stretch fraying

Figure 3.1
Ton container blocking

If more than six containers are to be secured with one set of chains, a higher strength chain
must be considered. See 49 CFR 393.106 and 393.108 for more details on various working
load limit requirements (9.2.1). Nylon straps should only be used to secure individual ton
containers. Articles of cargo that are likely to roll must be restrained by chocks, wedges,
cradles or other equivalent means to prevent rolling (see 49 CFR 393.106(c)) (9.2.1) (See
Figure 3.1). The front bulkhead should be reinforced as illustrated in Figure 3.2.
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 11

Figure 3.2
Front bulkhead reinforcement for ton containers

When transporting by flatbed trailers, side rails or other devices are commonly used for
proper bracing to prevent lateral movement of the ton containers (see 49 CFR
393.102(c)(2)) (9.2.1). Square, tubular construction of the side rails and cross members is
specified and detailed in Section 2.2.1. Rear roll-off protection must be provided.

A reinforced, removable guard rail or a 15 inch high contour fitting steel chock anchored
behind the rear-most container to the truck bed with pins or chains is an effective restraint.
Joining the two rear-most containers at the chimes with 8 inch drop-forged "C" clamps can
help prevent containers from rolling and is a recommended practice (Figure 3.3). The "C"
clamp should be secured to the vehicle in case it becomes loose.

Figure 3.3
C clamp on two end ton containers of truck load
12 PAMPHLET 76

3.1.4 Trailer Loading and Unloading Equipment

There are a number of trailers operated by chlorine packagers which have equipment
mounted on the trailer to load and unload ton containers. Fixed, mounted, hydraulic,
telescoping booms, traveling booms, and overhead, mono-railed chain hoists are in this
category. Proper training in the operation of these trucks is essential. If overextended, it
can cause a lack of stability to the trailer and/or damage to the crane. (Figure 3.4)

Figure 3.4
Telescopic boom mounted on ton container trailer

One method of securing ton containers on this type of equipment is with individual cradles
and lockdown devices (Figure 3.5).

Figure 3.5
Ton container lockdown devices
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 13

Alternate methods include use of individual stationary chocks and 3/8 inch proof-coil chains
(35,000 lbs minimum breaking strength for up to six ton containers) with load binders to
secure the tons to the bed. If more than six containers are to be secured with one set of
chains, a higher strength chain must be considered. See 49 CFR 393.106 and 393.108 for
more details on various working load limit requirements (9.2.1). Where individual cradles
and lockdown devices are not used, the recommendations stated in Section 3.1.2 for side
rails, front bulkhead, and rear roll-off protection apply. This pamphlet will make no attempt to
cover the safety considerations in operating specialized self-loading and unloading
equipment for chlorine ton containers that are mounted on the trailers. Following the
manufacturers instructions is important.

3.2 TON CONTAINER LOADING AND UNLOADING

The use of lifting beams either on the overhead cranes, traveling electric hoists, or forklift
trucks is frequently employed by shippers and customers for loading and unloading ton
containers. Proper design of the lifting beam is essential. A typical design is provided in CI
Drawing 122 (9.1). A majority of packaging plants use forklift trucks for handling ton
containers. Some use special attachments designed specifically for ton containers or extra-
long forks with tilt capabilities. Extreme care must be exercised when operating forklift
trucks in ton container service. Among considerations are:

roll-off restraint on forks


must be rated at a 4,000 lb minimum lifting capacity
side shifters for forks
use only on smooth surfaces
avoid speeding
avoid sharp turns
proper spacing of forks

Trailers and trucks may be equipped with electric or hydraulic tailgates (5000 lbs minimum
capacity). While raising or lowering the tailgate a positive means of preventing the ton
container from rolling off must be provided. Recommended methods include removable
chocks pinned into the floor or heavy duty pipes with welded stops. These are dropped into
slightly larger diameter holes in the tailgate floor. Proper training of personnel to guard
against strains, toe injuries, etc. is important when moving ton containers manually. Devices
such as a chime wrench may be used to facilitate moving ton containers. Provision for
securing or restraining the lever binder handle should be made to prevent it from working
loose. Overextending the fasteners can cause them to flip open and injure the operator
sometimes catapulting an operator off the truck. The use of lever binders on cables and
over-center type clamps are not recommended.

3.3 DOUBLE STACKING TON CONTAINERS


Double stacking of full ton containers on trailers is not recommended unless the trailers are
equipped with specially designed cradles and lockdown devices. Empty ton containers may
be double stacked on trailers provided adequate securement is provided to prevent
movement in transit (some suggested methods are: clamped to bottom row, extended side
rails).
14 PAMPHLET 76

4. COMBINATION SHIPMENTS

4.1 CYLINDER AND TON CONTAINERS

Chlorine cylinders and ton containers are frequently shipped together as combination loads.
When shipping chlorine cylinders and ton containers in combination careful thought must be
given to the securement requirements detailed in Sections 2 and 3 of this pamphlet.

4.2 CHLORINE AND OTHER CHEMICAL SHIPMENTS

Shipments of chlorine cylinders and one ton containers are sometimes combined with other
hazardous and non-hazardous chemicals. The Segregation Table for Hazardous Materials
located in 49 CFR 177.848 deals with the separation and segregation of hazardous
materials (9.2.1). This table and the accompanying instructions give clear guidance on
whether certain classes or divisions of hazardous materials can be loaded together, and
what restrictions, if any, apply when they are loaded together.

DOT has provided guidance in regulatory interpretation responses, particularly Reference


Numbers 08-0143 and 08-0201 (9.2.3 and 9.2.4), to help shippers comply with the
regulations when two materials must be separated in such a way that in the event of
leakage from packages under conditions normally incident to transportation, commingling of
hazardous materials would not occur. These interpretations include guidance on placing
barriers between packages inside of the transport vehicle, as long as they are sufficient to
keep the materials from commingling, including:

impediments
obstructions
dividers
packages of non-hazardous materials
non-reactive freight
non-permeable barriers
non-combustible, non-reactive absorbents
intervening space

Although the regulations do not specify a minimum segregation distance, separation by a


distance of 4 feet in all directions is considered acceptable by the DOT. The DOT has made
it clear that the integrity of the container is not considered an acceptable barrier. Canadian
Regulations pertaining to segregation can be found in the Transportation of Dangerous
Goods Act and Regulations (See Section 7.1).
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 15

5. PRIVATE AND COMMON CARRIERS

5.1 COMMON CARRIERS

The use of common carriers for transporting cylinders and ton containers of chlorine requires
careful consideration. The shipper must be certain that any and all employees (drivers,
warehouse and others) involved in any way with the preparation for transportation of
hazardous materials are properly trained, and the training is documented per DOT
requirements. In an emergency the driver may become involved in the implementation of
emergency plans. Drivers need to be familiar with the details of such a plan. The shipper
must confirm that the carrier uses only drivers with valid commercial drivers licenses with
the required hazardous materials endorsement. It is recommended that shippers use some
form of carrier selection checklist to evaluate the use of current and new carriers.

5.2 HAZARDOUS MATERIALS SAFETY PERMIT

Regulations require that any carrier who transports (among other hazardous commodities) a
shipment of Hazard Zone B materials in a bulk packaging (capacity greater than 450 L [119
gallons]) must apply for and be awarded a Hazardous Materials Safety Permit. Criteria for
the permit is maintaining a Satisfactory Rating and can be found in the DOTs Federal Motor
Carrier Safety Administrations (FMCSAs) regulations under 49 CFR Part 385 (9.2.1). As
chlorine is a Hazard Zone B material and ton containers have a water capacity greater than
119 gallons, any carrier transporting chlorine must be in possession of this document.

Carriers transporting materials that require such a permit must develop a communications
log where the motor carrier is advised by the driver that the shipment arrived as scheduled.
Logs must be maintained for a period of six months, in accordance with 49 CFR
385.415(c)(1) (9.2.1).

5.3 SECURITY PLAN

Regulations require that hazardous materials carriers develop and institute a Transportation
Security Plan as described in 49 CFR Part 172 Subpart I (9.2.1). At a minimum, the security
plan must include the following elements: Personnel Security, Unauthorized Access and En
Route Security. When developing these plans requirements of CIs Security Management
Plan for the Transportation and On-Site Storage and Use of Chlorine Cylinders, Ton
Containers and Cargo Tanks should be considered. The U.S. Department of Homeland
Securitys Transportation Security Administration (TSA) has issued recommendations to
help carriers develop, implement, and revise their security plans (see Section 8.2).

All hazmat employees must receive training on the contents of the carriers plan (49 CFR
172.704) (9.2.1). As the carrier plan is considered a safety sensitive document it is not
appropriate to request a copy of this plan from your carrier. Rather you should obtain
certification by the carrier that the plan is in place and conforms with all applicable
requirements.
16 PAMPHLET 76

5.4 SECURITY AWARENESS TRAINING

Regulations require that hazardous materials carriers develop and institute a Security
Awareness Training program as described in 49 CFR Part 172 Subpart H (9.2.1). All
hazmat employees must receive this training. New hazmat employees must obtain this
training within 90 days after employment.

5.5 PHMSA REGISTRATION

All carriers transporting hazardous materials must register with the Pipeline and Hazardous
Material Safety Administration (PHMSA) (49 CFR Part 107 Subpart G) (9.2.1). Evidence of
this registration must be carried in the transport.

5.6 SHIPPING PAPERS

In order to relinquish a parcel of any hazardous material, the shipper must prepare and
forward, along with the commodity, a shipping paper that complies fully with 49 CFR 177.817
(9.2.1). A 24-hour emergency phone number is required on the shipping papers in a manner
that is clearly visible so that it is quick and easy to find (49 CFR 172.604) (9.2.1).

5.7 PREVENTATIVE MAINTENANCE PROGRAM

It is recommended that all equipment used in handling chlorine cylinders and containers
be part of a Preventive Maintenance Program. This program should include procedures
and inspections specific to the equipment used. Typical equipment used in the handling
of chlorine cylinders and containers include, but are not limited to, equipment such as
forklifts, cranes, pallet jacks, and the like.

It is common practice that forms and/or checklists be used to document compliance with
company policy and equipment manufacturer recommendations. Carriers are encouraged to
develop their own forms/checklists based on their own company policies and operations.

5.8 PERSONAL PROTECTIVE EQUIPMENT

Exposure to chlorine can occur whenever chlorine is handled. It is recommended that


drivers transporting chlorine cylinders or ton containers have at least a minimum level of
protection in cases of chlorine emergencies. For selection considerations, as well as other
requirements, please refer to CI Pamphlet 65 (9.1).

6. EMERGENCY RESPONSE

6.1 CHLOREP

The Chlorine Emergency Plan (CHLOREP) is an industry-wide program established by the


Institute to improve the speed and effectiveness of response to chlorine emergencies in the
United States and Canada.
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 17

Under this plan the United States and Canada have been divided into regional sectors
where chlorine emergency teams from producing, packager, and consuming plants are on
constant alert on a 24-hour basis, to handle threatened or actual chlorine leaks. During a
chlorine emergency, any carrier, customer, or civil authority can obtain basic emergency
information and be put in contact with the closest chlorine emergency group by phoning an
emergency dispatch agency, such as CHEMTREC (See Section 6.2).

6.2 CHEMTREC AND CANUTEC

For transportation-related incidents in the U.S., one should utilize CHEMTREC, the
Chemical Transportation Emergency Center in Falls Church, VA, as the dispatch agency.
CHEMTREC operates around-the-clock, 24 hours-a-day, seven days-a-week to receive
direct-dial, toll-free calls from any point in the United States and Canada at 1-800-424-9300
(703-527-3887 for all other calls). CHEMTREC provides immediate advice for those at the
scene of emergencies, then, if the emergency involves chlorine, promptly contacts the
designated CHLOREP team, the shipper and others as required. Registration with
CHEMTREC is provided through the American Chemistry Council. In Canada, one should
utilize CANUTEC, the Canadian Transport Emergency Centre in Ottawa as the dispatch
agency. Their telephone number is 613-996-6666 (call collect). CANUTEC, administered
by TC, operates in a similar manner to CHEMTREC.

6.3 PERSONAL PROTECTIVE EQUIPMENT

Chlorine Institute Pamphlet 65 (9.1) provides information on personal protective equipment


for chlorine. Since it is unlikely the concentration of chlorine present in an emergency
situation can be adequately monitored, it is recommended that full face self-contained
breathing apparatus (SCBA) with at least 20 minutes of air operated in the positive pressure
mode be on-site and readily available.

6.4 REPORTING OF RELEASE

For on-site releases, chlorine is identified as a hazardous substance in Table 302.4 List of
Hazardous Substances and Reportable Quantities of 40 CFR 302.4 (9.2.1). CERCLA
requires immediate notification of a release equal to or in excess of the reportable quantity.
The reportable quantity of chlorine is 10 lbs (4.54 Kg.). Should a reportable release occur in
the U.S., the law requires the National Response Center (1-800-424-8802 or
http://www.nrc.uscg.mil) be immediately notified.

Any release of hazardous materials in transportation requires submitting a Hazardous


Materials Incident Report on DOT Form F 5800.01 within 30 days of discovery of the
incident. (See 49 CFR 171.15 and 16 for details) (9.2.1).

In Canada appropriate provincial response authorities must be immediately advised of a


chlorine release of any quantity. State, provincial and local laws may require reporting to the
appropriate state and/or local environmental agencies.
18 PAMPHLET 76

6.5 EMERGENCY KITS

Leaks that may occur in chlorine cylinders and ton containers usually involve the valves or
fusible plugs, which can be controlled with the Institutes Emergency Kit A, for 100- and
150-lb cylinders, and Kit B, for ton containers. The emergency kits should be in a location
sufficiently away from the containers so they will be accessible during an emergency. The
kits should be inspected frequently to ensure the equipment is ready for use. See 49 CFR
173.3(e) (9.2.1) for details on the use of emergency kits. If the source of the leak is other
than the valve or fusible plug, it is recommended to contact DOT to verify if a special permit
is required to transport the repaired container.

It is a violation of the Hazardous Materials regulations to ship any container that is leaking or
may experience leakage under conditions normally experienced during transportation,
however the DOT allows the shipment of damaged or leaking chlorine cylinders and ton
containers under certain conditions. Each shipper or carrier must become familiar with
these requirements and how they apply to their specific operation.

Information regarding one-way transport of a leaking chlorine cylinder can be found in 49


CFR Part 173.3(d) (9.2.1). This paragraph allows for the use of a recovery vessel to
transport a damaged or leaking 150 lb chlorine cylinder in certain situations. Details include
construction, marking and labeling requirements, shipping papers and cleaning the cylinder
after use. Detailed information can be obtained in the CFR and through some of the
references in Section 8.

Guidelines for the use of the emergency kits and recovery vessel may be found in CI
pamphlets titled Chlorine Institute Emergency Kit "A" for 100 lb and 150 lb Chlorine
Cylinders, Chlorine Institute Emergency Kit "B" for Chlorine Ton Containers, and Chlorine
Institute Recovery Vessel for 100 lb and 150 lb Chlorine Cylinders, and their respective
videos (9.1).

7. TRAINING

7.1 GENERAL

Every person working with chlorine should be trained to ensure safe handling of the product
during packaging, storage, and transportation. All hazmat employees should know the
proper ways to handle chlorine, should know how to use appropriate protective devices and
PPE, should know methods of detecting hazards, and should know what to do in case of an
emergency.
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 19

7.2 MANDATORY TRAINING REQUIREMENTS

Personnel involved in the loading, unloading, inspection, or shipping of hazardous materials


must be properly trained. Mandatory training requirements have been established by DOT
and Transport Canada. DOT hazmat employee training requirements are found in 49 CFR
172.700 and 174.704 (9.2.1) and include:

General awareness
Function-specific training
Safety training
OSHA and EPA training
Training record retention

Driver training requirements may be found in 49 CFR 177.800 and 177.816 (9.2.1) and
includes:

Pre-trip driver inspections


Use of vehicle controls
Operation of vehicle
Attendance and parking
Loading and unloading
Cargo compatibility
Package handling
Load securement

Additional driver requirements may be found in 49 CFR Parts 383, 386 and 390-397 (9.2.1).
For Canadian training requirements refer to Section 8.3.

8. REGULATIONS

8.1 DOT REGULATIONS

The DOT regulates the acceptance and transportation of hazardous materials in the United
States. DOT's Pipeline and Hazardous Materials Safety Administration (PHMSA) and
Federal Motor Carrier Safety Administration (FMCSA) regulate the transportation of chlorine
by highway in the U.S. PHMSA's Hazardous Materials Regulations are found in 49 CFR
Parts 171 to 180 (9.2.1). These parts include the classification of materials, loading and
unloading operations and methods for hazard communication like marking, labeling, and
placarding. The transportation of hazardous waste is also included in these regulations.
Because chlorine is a hazardous material, it is imperative that personnel involved in any
aspect of handling, packaging, and/or transportation of chlorine are knowledgeable of the
regulatory requirements pertaining to chlorine. FMCSAs Motor Carrier Safety regulations
are found in 49 CFR parts 40, 380, 382, 383, 387, 390, 391-397, 399, and Appendix G
(9.2.1). These regulations cover topics such as the action of the drivers and maintenance of
the vehicles.
20 PAMPHLET 76

8.2 TSA RECOMMENDATIONS

The TSA has established security action items that motor carriers should consider for the
development, implementation, and revision of their security plans for Tier 1 and Tier 2
highway security-sensitive materials (HSSM). These action items are voluntary to allow
highway motor carriers to adopt measures best suited for their particular practices. The
security action items are divided into four categories:

1. General Security
2. Personnel Security
3. Unauthorized Access
4. En Route Security

These security action items allow for flexibility based upon the assessed vulnerability of a
particular process or operation. See TSAs memo to highway and motor carrier security
partners dated June 26, 2008, as well as the action memo for modification dated May 20,
2009, for more details (9.3.1).

8.3 CANADIAN REGULATIONS

Canadian Regulations are covered by Transport Canada in the Transportation of Dangerous


Goods Act and Regulations. The Transport of Dangerous Goods Act is the authority under
which dangerous goods are regulated. The Act supersedes the Regulations.

The Transportation of Dangerous Goods Regulations are made under the Authority of the
Act. There 16 parts to regulations which cover such items as Interpretations, General
Provisions, Classification, Documentation, Dangerous Goods Safety Marks, Means of
Containment, Training, Emergency Response Plan, and Accidental Release and Imminent
Accidental Release Report Requirements. Shippers must become familiar with these
regulations and how they could affect their operation.

Requirements for the safe motor vehicular transportation of chlorine in cylinders and ton
containers can be found in Parts 1-16 of the regulation (9.4.1). Shippers of cylinders and ton
containers need to be aware there are three (3) schedules to the regulations.

8.4 OTHER REGULATIONS


Chlorine is also regulated under FIFRA (Federal Insecticide, Fungicide and Rodenticide Act)
and CERCLA (Comprehensive Environmental Response, Compensation and Liability Act of
1980). These regulations are outside the scope of this pamphlet.
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 21

9. REFERENCES

9.1 CHLORINE INSTITUTE REFERENCES

The following publications are specifically referenced in CI Pamphlet 76. The latest editions
of CI publications may be obtained at http://www.chlorineinstitute.org.

Pamphlet,
DVD & Title
Drawing #

65 Personal Protective Equipment for Chlor-Alkali Chemicals; Ed. 5,


Pamphlet 65; The Chlorine Institute: Arlington, VA, 2008.

IB/A Instruction Booklet: Chlorine Institute Emergency Kit "A" for 100 lb
and 150 lb Chlorine Cylinders; Ed. 11, Pamphlet IB/A; The Chlorine
Institute: Arlington, VA, 2009.

IB/B Instruction Booklet: Chlorine Institute Emergency Kit "B" for Chlorine
Ton Containers; Ed. 10, Pamphlet IB/B; The Chlorine Institute:
Arlington, VA, 2009.

IB/RV Instruction Booklet: Chlorine Institute Recovery Vessel for 100 lb and
150 lb Chlorine Cylinders; Ed. 2, Pamphlet IB/RV; The Chlorine
Institute: Arlington, VA, 2009.

A-DVD The Chlorine Institute Emergency Kit A and Recovery Vessel


Instructional Video, A-DVD; Ed. 3, The Chlorine Institute: Arlington,
VA, 2009.

B-DVD Emergency Kit B for Chlorine Ton Containers; Ed. 2, B-DVD; The
Chlorine Institute: Arlington, VA, 2006.

DWG 122 Ton Container Lifting Beam, Drawing; Ed. 2, DWG 122; The Chlorine
Institute: Arlington, VA, 1993.
22 PAMPHLET 76

9.2 DOT REGULATIONS

9.2.1 Code of Federal Regulations. Title 49. Parts 100-399. Office of the Federal Register
National Archives and Records Administration. U.S. Government Printing Office:
Washington, DC, (revised annually). Web site: http://www.gpoaccess.gov/cfr/index.html.

9.2.2 North American Emergency Response Guidebook. Office of Hazardous Materials


Initiatives and Training, DHM-50,
(http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/Hazmat/ERG2012.pdf)
Pipeline and Hazardous Materials Safety Administration, U.S. Department of
Transportation: Washington, DC, 2012.

9.2.3 Interpretation #08-0143. Office of Hazardous Materials Standards (PHH-10),


(http://www.phmsa.dot.gov/hazmat/regs/interps), Pipeline and Hazardous Materials
Safety Administration, U.S. Department of Transportation: Washington, DC, 2008.

9.2.4 Interpretation #08-0201. Office of Hazardous Materials Standards (PHH-10),


(http://www.phmsa.dot.gov/hazmat/regs/interps), Pipeline and Hazardous Materials
Safety Administration, U.S. Department of Transportation: Washington, DC, 2008.

9.3 TSA RECOMMENDATIONS

9.3.1 Highway Security-Sensitive Materials (HSSM) Security Action Items, Transportation


Security Administration, U.S. Department of Homeland Security: Arlington, VA, 2008.
Web site: http://www.tsa.gov/what_we_do/tsnm/highway/hssm_sai.shtm.

9.4 TRANSPORT CANADA REGULATIONS

9.4.1 Canadian Transportation of Dangerous Goods Act and Regulations, Transport Canada:
Ottawa, Ontario, 2009. Web site: http://www.tc.gc.ca/tdg.
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 23

9.5 OTHER CHLORINE INSTITUTE PUBLICATIONS

The following publications provide useful information in addition to the publications reference
herein. The latest editions of CI publications may be obtained at
http://www.chlorineinstitute.org.

Pamphlet # Title

1 Chlorine Basics (Formerly The Chlorine Manual); Ed. 7,


Pamphlet 1; The Chlorine Institute: Arlington, VA, 2008.

17 Packaging Plant Safety and Operational Guidelines; Ed. 4-R2,


Pamphlet 17; The Chlorine Institute: Arlington, VA, 2011.

64 Emergency Response Plans for Chlor-Alkali, Sodium


Hypochlorite, and Hydrogen Chloride Facilities; Ed. 6-R1,
Pamphlet 64; The Chlorine Institute: Arlington, VA, 2008.
24 PAMPHLET 76

For further assistance and information on items referenced, contact the following organizations:

Director, Office of the Federal Register American Trucking Association


National Archives and Records Administration 950 Glebe Road, Suite 210
8601 Adelphi Road Arlington, VA 22203-4181
College Park, MD 20740-6001 703-838-1700
1-866-272-6272 www.truckline.com
www.archives.gov/federal-register

Superintendent of Documents National Association of Chain


Government Printing Office Manufacturers
Washington, DC 20402 P.O. Box 89014
202-512-1800 (sales) Tucson, AZ 85752-9014
www.goaccess.gov/databases.html 520-886-0695
www.nacm.info

The Chlorine Institute Transport Canada


1300 Wilson Boulevard, Ste. 525 330 Sparks Street
Arlington, VA 22209 Ottawa, ON K1A 0N5
703-894-4140 866-996-9737 (toll free)
703-894-4130 (Fax) 613-990-2309 (direct)
www.chlorineinstitute.org 613-954-4731 (fax)
www.tc.gc.ca
GUIDELINES FOR THE SAFE MOTOR VEHICULAR TRANSPORTATION
OF CHLORINE CYLINDERS AND TON CONTAINERS 25

APPENDIX A

PAMPHLET 76 CHECKLIST

This checklist is designed to emphasize major topics for someone who has already read and
understood the pamphlet. Taking recommendations from this list without understanding
related topics can lead to inappropriate conclusions.

Place a check mark ( ) in the appropriate box below:

Yes No N/A GENERAL QUESTIONS

1. Are all employees involved with the transportation of chlorine


containers properly trained as specified in 49 CFR or Transport
Canadas, Transport of Dangerous Goods Act & Regulations?

2. If a common carrier is being used, are their drivers properly


trained and do they know how to activate the emergency
response plan?

3. Is the decking on the truck in suitable condition and of


acceptable materials of construction?

4. Are the correct placards displayed correctly on the four sides of


the truck?

5. Are the shipping papers correct including name, hazard,


quantity, RQ, etc.?

6. Is the loading and unloading equipment designed to handle the


weight of the full containers or of full cylinders including the
weight of pallets?

7. Are containers properly secured to the unloading device before


lifting them or moving them?

8. If chlorine containers are part of a mixed shipment with other


hazardous materials, are DOTs separation table requirements
in 49 CFR being met?

100 and 150 lb Cylinders

9. Are they upright and properly secured in at least two places?

10. Are the chains or straps used to secure them in good condition?
26 PAMPHLET 76

Yes No N/A GENERAL QUESTIONS

Ton Containers

11. Is the bulkhead properly reinforced and designed to secure


tons?

12. Are the individual containers chocked to prevent rolling?

13. If chains are used, do they meet DOT or Transport Canada


requirements for the combined weight of the containers they
secure?

14. Are nylon straps only used to secure an individual ton container?

15. Are you using a C clamp to connect the two end containers at
the chimes and is the clamp secured to the vehicle in case it
becomes loose?

16. If individual lockdown devices are used, are all tons properly
secured and is each device in the fully locked position?

REMINDER:

Users of this checklist should document exceptions


to the recommendations contained in this pamphlet.
1300 Wilson Boulevard Suite 525 Arlington, VA 22209
Telephone: (703) 894-4140 Fax: (703) 894-4130
Email: pubs@CL2.com Website: www.chlorineinstitute.org
THE CHLORINE INSTITUTE Technical inquiries: techsvc@cl2.com

The Chlorine Institute all rights reserved.

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