Interpretation Response #05-0114 ([HazMat Environmental Group, Inc.] [Ms. Colleen A. Orth])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HazMat Environmental Group, Inc.
Individual Name: Ms. Colleen A. Orth
Location State: NY Country: US
View the Interpretation Document
Response text:
Jul 27, 2005
Ms. Colleen A. Orth Reference No. 05-0114
Compliance Officer
HazMat Environmental Group, Inc.
New Village Industrial Park
60 Commerce Drive
Buffalo, New York 14218-1040
Dear Ms. Orth:
This responds to your April 27, 2005 letter requesting clarification on "closed bulk bins" under § 173.240 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a box van trailer is a "closed bulk bin." You also ask about marking requirements for the bulk packaging.
Section 173.240 authorizes the transportation of certain low hazard solid materials in non-DOT specification sift-proof closed bulk bins. In order to be considered sift-proof; the completed package may not permit the escape of any of the hazardous material contained therein. A "closed bulk bin" is a type of bulk packaging other than a portable tank, cargo tank, tank car and multi-unit tank car. It is the shipper"s responsibility to ensure that the packaging provides sift-proof containment at the time of shipment and will continue to provide that containment until the package reaches its final destination. It is the opinion of this Office that a box van trailer is a "closed bulk bin" if the provisions of § 173.240 requiring sift-proof containment are met.
In addition to being sift-proof and closed, the package must also meet general packaging provisions of § 173.24 and I 73.24b. The bins are also subject to the requirements of the special provisions contained in Column 7 of the Hazardous Materials Table (HMT; 172.101), as applicable to the material being transported.
If the Class 9 material is packaged in a non-specification sift-proof closed bulk bin in accordance with § 173.240(c), the marking requirements in § 172.302, 172.33 1 and 172.332 apply. Specifically, the bulk container must be marked with the appropriate 4-digit UN identification number in the prescribed format. A Class 9 placard is not required for domestic transportation.
I hope this answers your inquiry.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.240
Regulation Sections
| Section | Subject |
|---|---|
| 173.240 | Bulk packaging for certain low hazard solid materials |