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Interpretation Response #02-0279 ([Bay Zinc Company, Inc] [Jennifer Clemenson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bay Zinc Company, Inc

Individual Name: Jennifer Clemenson

Location State: WA Country: US

View the Interpretation Document

Response text:

Dec 11, 2002

Ms. Jennifer Clemenson                    Reference No.02-0279
Sales Assistant
Bay Zinc Company, Inc.
P.O. Box 167
Moxee, WA 98936

Dear Ms. Clemenson:

This is in response to your letter dated October 30, 2002, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you request information on the shipping paper, packaging, hazard communication, and loading requirements for a material described as "Environmentally hazardous substance, solid, n.o.s., 9, UN 3077, III" transported in 50 pound bags, 2,000 pound bags, and 25-35 ton bulk trucks.

As provided by § 172.504(f)(9), when transported domestically a CLASS 9 placard is not required to be displayed on a transport vehicle containing packages of a Class 9 material (e.g., bags, IBCs or dry-bulk trailer).  Each non-bulk packaging, unless otherwise excepted, must be marked in accordance with Part 172, Subpart D and labeled in accordance with Part 172, Subpart E. Bulk packagings containing a Class 9 material must be marked with the appropriate identification number displayed on a CLASS 9 placard, an orange panel, or a white square-on-point display configuration.

For a material properly described as "Environmentally hazardous substance, solid, n.o.s., 9, UN 3077, III" the bulk and non-bulk packaging requirements are found in §§ 173.240 and 173.213, respectively.  The shipping paper requirements are found in Part 172, Subpart C and, for transportation by highway, the loading and unloading requirements are located in Part 177, Subpart B.

I hope this satisfies your request.


John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.504 General placarding requirements