Interpretation Response #04-0117 ([Fomo Products Inc.] [Mr. Timothy J. Eberling])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Fomo Products Inc.
Individual Name: Mr. Timothy J. Eberling
Location State: OH Country: US
View the Interpretation Document
Response text:
Sep 7, 2004
Mr. Timothy J. Eberling Reference No. 04-0117
Safety and Regulatory Manager
Fomo Products Inc.
2775 Barber Road
Norton, Ohio 44203
Dear Mr. Eberling:
This is in response to your letter dated May 4, 2004 regarding the loading requirements for Class 2 (gases) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask whether the requirements in § 177.840(a) prohibit DOT 39 specification cylinders that are packaged in 4G packaging and palletized from being doubled stacked.
The answer is no. Non-bulk packagings including cylinders containing hazardous materials may be stacked or "double stacked" in a transport vehicle provided, as stated in § 177.840(a) the floor or platform is essentially flat. Although, the HMR do not prohibit stacking, a person loading hazardous materials in non-bulk packagings (e.g., 4G boxes) into a transport vehicle must determine whether stacking could reduce the integrity of the packages.
I trust this satisfies your request.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
177.840
Regulation Sections
| Section | Subject |
|---|---|
| 177.840 | Class 2 (gases) materials |