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Interpretation Response #02-0068

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

Interpretation Response Details

Response Publish Date:

Company Name: McClain E-Z Pack, Inc

Individual Name: Jamie S.Morton-Richardson

Location State: OK Country: US

View the Interpretation Document

Response text:

March 22, 2002

Ms. Jamie S. Morton-Richardson Reference No. 02-0068
McClain E-Z Pack, Inc.
4000 S.W. 113th
Oklahoma City, OK 73173

Dear Ms. Morton-Richardson:

This is in response to your request for clarification of authorized packagings for "Solids containing flammable liquid, n.o.s.," UN3175 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask whether a roll-on/roll-off bulk container is authorized for this entry. You also ask whether Special Provision 47 means that a leakproofness test at the Packing Group II level must be performed on a roll-on/roll-off bulk container.

Section 173.240 authorizes sift-proof non-DOT specification closed bulk bins for "Solids containing flammable liquid, n.o.s.," UN3175. Roll-on/roll-off bulk containers that are strong, firm, durable, constructed so that they are securely closed whereby contents cannot pass through, and meet the applicable requirements in '' 173.24 and 173.24b are authorized non-DOT specification closed bulk bins and do not require a leakproofness test. Provided these requirements are met, "Solids containing flammable liquid, n.o.s." meeting Special Provision 47 may be transported in the roll-on/roll-off bulk containers.

I hope this information is helpful. Please contact us if you have additional questions.


Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.240 Bulk packaging for certain low hazard solid materials