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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0035 ([Transportation Safety Compliance Service] [Mr. Darwin D. Garvin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Transportation Safety Compliance Service

Individual Name: Mr. Darwin D. Garvin

Location State: FL Country: US

View the Interpretation Document

Response text:

February 23, 2000

Mr. Darwin D. Garvin                Ref. No: 00-0035
Transportation Safety
Compliance Service
1805 Westininister Court
Lakeland, Florida 33809

Dear Mr. Garvin:

This is in response to your letter of December 13, 1999, requesting clarification on the requirements for transporting molten sulfur under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80).  Specifically you ask whether a cargo tank containing only the residue of molten sulfur which is no longer at an elevated temperature is still subject to the HMR.  You state the cargo tank would contain only a small thin solid coating of sulfur.

The answer is no.  As provided by special provision 30 (§ 172.102), sulfur is not subject to the HMR if formed to a specific shape.  It is the opinion of this Office that because the solid sulfur residue in a cargo tank is formed into a shape (the shape of the shell of the cargo tank) it is not subject to the HMR.  We are unable to respond to your question regarding vehicles stopping at railroad crossings.  You may contact Mr. Larry Minor of the Federal Motor Carrier Safety Association at (202) 366-1790 for information on this issue.

I hope this information is helpful.


Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections