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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 #00-0064 ([Mr. Tom Kennedy] [Independent Container Line Ltd.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mr. Tom Kennedy

Individual Name: Independent Container Line Ltd.

Location State: VA Country: US

View the Interpretation Document

Response text:

April 6, 2000

Mr. Tom Kennedy                Ref. No.00-0064

VP Marine Operations

Independent Container Line Ltd.

4801 Audubon Dr.

Richmond, VA 23231

Dear Mr. Kennedy:

This is in response to your letter of February 22, 2000, concerning segregation requirements for limited quantities of hazardous materials shipped under the Hazardous Materials Regulation (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code.  Your request concerned the packaging of limited quantities of Oxidizing solid, NOS and Hydrogen Peroxide, aqueous solution in a freight container.

As you point out in your letter, § 176.80(b) and Paragraph 18.6.2 of the General Introduction of the IMDG Code except hazardous materials in limited quantities from the segregation requirements of each set of regulations.  However, § 173.21(e) and Section 20 entitled "Chemical Stability of Dangerous Substances" in the General Introduction of the IMDG Code, prohibit carrying materials together which could dangerously react.  While both sets of regulations state that oxidizing solids and hydrogen peroxide must be segregated, the exception from segregation for limited quantities allows these materials to be shipped together if the mixing of the two materials would not cause a dangerous evolution of heat, flammable or poisonous vapors, or to produce corrosive materials.  It is the responsibility of the offeror to determine if the quantity and characteristics of the materials would cause a dangerous evolution of heat, flammable or poisonous vapors if mixed.

I hope this satisfies your request.


Delmer F. Billings

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
176.80 Applicability