Interpretation Response #04-0204 ([ESS Group, Inc] [Ms. Kelly V. Camp])

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

Interpretation Response Details

Response Publish Date: 11/24/2004

Company Name: ESS Group, Inc

Individual Name: Ms. Kelly V. Camp

Location State: RI Country: US

View the Interpretation Document

Response text:

Nov 24, 2004

Ms. Kelly V. Camp                 Reference No. 04-0204

Senior Project Manager

ESS Group, Inc.

401 Wampanoag Trail

Suite 400

East Providence, RI 02915

Dear Ms. Camp:

This is u response to your letter dated August 27, 2004 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you are requesting further clarification of our August 12, 2004 letter addressed to you from Mr. John A. Gale. You ask about the classification, hazard precedence, and packing group of methanol for international transportation when it is mixed with other hazardous and non-hazardous materials. In addition, you ask if a pressure relief device is considered to be a vent for purposes of 173.24(g).

When shipping methanol internationally the authorized Hazardous Materials Table entry is identified by a plus sign in Column 1. The plus sign indicates that a material is known to pose a risk to humans and the proper shipping name, hazard class and packing group for that entry are fixed without regard to the hazards of the material. If you prepare an international shipment of methanol as a mixture with other hazardous and non-hazardous materials the final product may or may not exhibit the hazards of the original constitutes. To make that determination you must first determine the hazards of the material, either through testing in accordance with the hazard class definitions found in Part 173 of the HMR or based on your knowledge of the material. If you find that the hazards to humans are significantly different from that of the pure methanol or that no hazard to humans is posed, the material may be described using an alternative shipping name that represents the hazards posed by the material. In addition, an appropriate alternative proper shipping name and. hazard class may be authorized by the Associate Administrator. Based on the information you provided, it is our opinion that the methanol in the mixtures you describe is sufficiently diluted that it poses no toxicity hazard to humans.

When selecting a shipping description for your product you must assign a proper shipping name based on the hazards of the material and the most stringent packing group assigned to those hazards. If the hazards are Division 5.1, PG II and Class 3, PG II then the hazard class and packing group assigned to the material would be Division 5.1, PG II. If the hazards are Division 5.1, PG III and Class 3, PG II then the hazard class and packing group assigned to the material would be Division 5.1, PG II.

For purposes of the HMR, the terms "vent" and "pressure relief device" are not

considered to be synonymous. Therefore, § 173.24(g) does not apply to pressure relief devices.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A. Gale

Chief Regulations Development

Office of Hazardous Materials Standards

173.24

Regulation Sections