Interpretation Response #02-0209 ([FISC ATACHUB] [Libby Bishop])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: FISC ATACHUB
Individual Name: Libby Bishop
Location State: VA Country: US
View the Interpretation Document
Response text:
Nov 8, 2002
Ms. Libby Bishop Reference No. 02-0209
FISC ATACHUB
406 "B" St, Bldg DP-237
Norfolk, VA 23511
Dear Ms. Bishop:
This responds to your August 16,2002 letter. requesting clarification on the correct method of shipping "empty" fuel tanks and fuel pumps by commercial motor vehicle under the Hazardous Materials Regulations (HMR;.49 CFR Parts 171-1180). Specifically, you ask if you may ship fuel pumps and tanks that have been drained, but not purged and may contain a trace of JP-5 jet fuel as a Combustible liquid under §173.150(f)(2)and(f)(3).
You state that you were advised by a DOT representative that. you may ship the fuel pumps under the provisions of § 173.150(t)(2) as non-regulated, and use non-specification boxes for your freight. You were also advised that you may ship the fuel tanks under §. 1,73.150(f)(3) as "Combustible liquid, 3, NA 1993" with no label. You request written confirmation from us on the shipping information provided to you by a DOT representative.
Section 173.29 requires that an empty packaging containing a residue of a hazardous material be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material,. unless it has been sufficiently cleaned of residue and purged of vapors to remove any potential hazard. You state in your letter that your fuel pumps and tanks may contain a trace of JP-5 jet fuel; therefore, they must be shipped in the same manner as when they previously contained JP-5 jet fuel. However, if the JP-5 jet fuel has a flash point at or above 100 degrees farenheight and does not meet the definition of any other hazard class, it may be reclassed as a Combustible liquid and shipped by highway or rail according to provisions specified in § 173.150(f).
I hope this answers your inquiry.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.150 & 173.29