Interpretation Response #00-0181 ([Samson Tug and Barge Company, Inc.] [Mr. Al Snelling])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Samson Tug and Barge Company, Inc.
Individual Name: Mr. Al Snelling
Location State: AL Country: US
View the Interpretation Document
Response text:
SEP 25, 2000 < p/>
Mr. Al Snelling Ref. No: 00-0181
Samson Tug and Barge Company, Inc.
P.O. Box 559
Sitka, Alaska 99835
Dear Mr. Snelling:
This is in response to your letter of June 13, 2000, requesting information concerning the transport of propane in an MC-330 / MC 331 cargo tank on a barge under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Your questions are paraphrased and answered as follows: < /p>
Ql. May propane be transported on a deck cargo barge in an MC 330/331 cargo tank either on a CFC cargo platform or in a roll on – roll off (ro-ro) fashion?
With respect to ro-ro transport, §176.7 6(b) requires transport vehicles containing hazardous materials to be carried only on trailership, trainship, ferry vessel or carfloat as those terms are defined in the HMR (refer to §171.8 for definitions). Depending on the type of service (route) in which it is engaged, a deck cargo barge suitable for that type of service could transport an MC 330/331 cargo tank as ro-ro cargo.
We assume that your reference to CFC platform was meant to be a reference to a container frame or flatrack that meets the provisions of the International Convention for Safe Containers (CSC Convention). An MC 330/331 cargo tank that is adequately secured on a container such as a flatrack that meets the provisions of 49 CFR 450 to 453 may also be transported on a deck cargo barge provided the barge is suitable for the type of service (route) in which it is engaged. Note that if the cargo tank is altered such that it no longer meets the definition of "cargo tank" (e.g., by removal of the pressure vessel portion of the cargo tank from the vehicle or trailer chassis), the foregoing does not apply. In a situation such as this where the pressure vessel is removed from its trailer chassis it would cease to meet the definition of a cargo tank and could only be used if authorized under a DOT exemption or remanufactured to an authorized DOT specification.
Q2. May propane be carried on a deck cargo barge in any fashion other than in a DOT 51 portable tank?
In addition to the manner discussed in the answer to question 1 above, propane also may be transported in certain non-bulk packagings (DOT specification cylinders) in accordance with §173.304 and otherwise in accordance with 49 CFR 176.
I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
176.76