Interpretation Response #03-0263 ([Clean Harbors Environmental Services, Inc.] [Ms. Susan J. Sevy])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 03/09/2005

Company Name: Clean Harbors Environmental
Services, Inc.

Individual Name: Ms. Susan J. Sevy

Location State: OH Country: US

View the Interpretation Document

Response text:

Mar 9, 2005

Ms. Susan J. Sevy                 Reference No. 03-0263
Transportation Compliance Manager
Clean Harbors Environmental
Services, Inc.
2930 Independence Road
Cleveland, Ohio 44115

Dear Ms. Sevy:

This responds to your letter requesting clarification of the segregation requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) - Specifically, you ask whether the segregation requirements of § 177.848 apply to separate transport vehicles parked at a 10-day temporary storage facility. The storage is incidental to transport. I apologize for the delay in responding.

We understand your question to relate to “packages which require labels” as specified in § 177.848(a) (1). As explained in § 177.848(e) (2), packages that contain incompatible hazardous materials (“X” in the segregation table) may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation. However, when the packages containing incompatible materials are in separate transport vehicles, those transport vehicles may be stored in the same storage facility during the course of transportation. In the latter scenario, the “packages” are not being “stored together” for purposes of the segregation requirements in § 177.848.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Edward T. Mazzullo
Director
Office of Hazardous Materials Standards

177.848

Regulation Sections