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Interpretation Response #02-0223 ([Hamburg-Sued, Aliamca and Crowley] [Dawn M. Abbaticchio])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hamburg-Sued, Aliamca and Crowley

Individual Name: Dawn M. Abbaticchio

Location State: NJ Country: US

View the Interpretation Document

Response text:

Apr 22, 2003

Ms. Dawn M. Abbaticchio                   Reference No. 02-0223
Hazardous Materials Specialist
Hamburg-Sued, Aliamca
 and Crowley
465 South Street
Morristown, NJ 07960

Dear Ms. Abbaticchio:

This responds to your inquiry regarding the requirements for segregation and forbidden materials and packages under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), as they apply to Class 8 (Corrosive) acids and "Potassium hydroxide solution" loaded on the same transport vehicle or freight container.  We apologize for the delay in responding and hope it has not caused any inconvenience.

You stated that the product contains "Potassium hydroxide, diluted to 1-5% concentration, and this concentration does not react dangerously or violently with acids when tested.  This product is sold to customers for the purpose of mixing the contents together for film processing, and no dangerous results have been exhibited.  You asked if this material is forbidden in accordance 49 CFR 173.21(e), and whether Class 8 (Corrosive) acids and your Potassium hydroxide solution may be loaded on the same transport vehicle or freight container.  You also asked if a Competent Authority Approval is required for shipment by vessel of your product to the U.S.

A material described as "Potassium hydroxide solution, 8, UN 1814, III" may be loaded together with acids on the same transport vehicle or freight container, provided they are not forbidden in accordance with § 173.21 (e).  Such determination is based on whether or not the mixing of a material in the same packaging, freight container, or overpack with another material is likely to cause a dangerous evolution of heat, or flammable or poisonous gases or vapors, or to produce corrosive materials. Based on the information provided that the mixing of the contents does not react violently and no adverse reaction occurs, the Potassium hydroxide, diluted to 1-5% concentration, identified in your letter is not a forbidden material under 49 CFR 173.21.

Under the HMR, the segregation requirements for transportation by highway specify that a hazardous material may not be loaded, transported, or stored together except as provided in 49 CFR 177.848(d). In addition, cyanides or cyanide mixtures may not be loaded or stored with acids if a mixture of the materials would generate hydrogen cyanide (See 49 CFR 177.848(c)). Therefore, if your product containing the Potassium hydroxide is not forbidden as specified in § 173.21 (e), it may be loaded or stored together with acids during transportation.

In accordance with the International Maritime Dangerous Goods (IMDG) Code, the stowage and segregation provisions in column (16) of the Dangerous Goods List for Potassium hydroxide solution, UN 1814, specify segregation of "Away From" acids"".  For segregation within cargo transport units, sub-section 7.2.2.3 provides the following: Dangerous goods which have to be segregated from each other shall not be transported in the same cargo transport unit with the exception of dangerous goods which shall be segregated "Away From" each other which may be transported in the same cargo transport unit with the approval of the competent authority.  In such cases, an equivalent standard of safety shall be maintained." As indicated earlier, you have provided information that the mixing of the contents does not result in a violent or adverse reaction.  Accordingly, it appears that a competent authority approval can be issued to allow transport of the dilute potassium hydroxide solution and the acid in the same cargo transport unit.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

Delmer F. Billing

Chief, Standards Development
Office of Hazardous Materials Standards

173.21

Regulation Sections

Section Subject
173.21 Forbidden materials and packages