Interpretation Response #03-0181 ([R and J Trucking] [Mr. Daniel J. Fire])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: R and J Trucking
Individual Name: Mr. Daniel J. Fire
Location State: OH Country: US
View the Interpretation Document
Response text:
Sep 4, 2003
Mr. Daniel J. Fire Reference No. 03-0181
Director of Safety
American Bulk Commodities, Inc. and Subsidiaries
R and J Trucking
8063 Southern Blvd
Youngstown, OH 44513
Dear Mr. Fire:
This responds to your July 10, 2003 letter requesting clarification on the use of Special Provision B115 under § 172.102 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification of this special provision when transporting “Aluminum smelting byproducts or Aluminum remelting by-products, 4.3, UN 3170, PG II” in a dump trailer motor vehicle covered by a roll tarp.
According to your letter, your driver was transporting the Aluminum remelting by-products in a dump trailer covered with a vinyl roll tarp. The driver received a citation from the Ohio State Highway Patrol for using a tarp that did not allow for venting as required under Special Provision B115. It is your understanding that the tarp used on your trailer does keep water out, and, also provides for venting where the tarp, sets on the sides and rear of the trailer.
Special Provision B115 authorizes the use of rail cars, highway trailers, roll-on/roll-off bins or other non-specification bulk packagings for transporting these aluminum by-products. Special Provision B115 also requires that these bulk packagings be sift-proof, prevent liquid water from reaching the hazardous material, and be provided with sufficient venting to preclude dangerous accumulation of flammable, corrosive, or toxic gaseous emissions such as methane, hydrogen, and ammonia. In addition, the material must be loaded dry. Based on the information and drawing of the dump trailer with tarp, provided in your letter, it is the opinion of this Office that your dump trailer covered with a vinyl roll tarp does meet all the requirements of Special Provision Bl15, including venting.
I hope this answers your inquiry.
Sincerely,
Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
172.102
Regulation Sections
| Section | Subject |
|---|---|
| 172.102 | Special provisions |