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Interpretation Response #02-0310

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

Interpretation Response Details

Response Publish Date: 04-03-2003
Company Name: Spray Chem Chemical Company, Inc.    Individual Name: Clifford L. Jacobson
Location state: CA    Country: US

View the Interpretation Document

Response text:

Apr 3, 2003

Mr. Clifford L. Jacobson                     Reference No. 02-0310
Spray Chem Chemical Company, Inc.
705 Keenan court
Durham, CA 95938

Dear Mr. Clifford:

This responds to your letter regarding the proper segregation and separation of a Division 5.1 (oxidizer) and a Class 8 (corrosive) liquid under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Q1. What is the definition of the term “separation” in the segregation and separation requirements specified in § 177.848 of the HMR.

A1. The term "separation" as it relates to the segregation of hazardous materials on a transport vehicle or freight container is not defined in the HMR.  Section 177.848(e)(3) states that accordingly during the course of transportation separation may be accomplished by some means of physical separation, such as non-permeable barriers, non-reactive freight, or noncombustible, non-reactive absorbents between packages of hazardous materials required to be separated.

Q2. You asked if the following scenario would be considered proper separation?

A 330 gallon Intermediate Bulk Container (IBC) containing 35% hydrogen peroxide (Division 5.1) is loaded onto a van with 55-gallon drums or an IBC containing Class 8 (corrosive) liquid.  The IBC containing the Division 5.1 (oxidizer) and the IBC or 55 gallon drums containing the Class 8 liquid are separated by placing other drums or IBCs containing non-hazardous material between them.  The frame of the IBC containing the HzO2 is elevated above the floor and has fork lift cut outs for loading and unloading.  The 55-gallon drums are elevated above the floor and placed on wooden or plastic pallets.

A2. The answer is yes.  The provisions for separation can be met by placing barriers (i.e., impediments, obstructions, dividers, packages of non-hazardous materials, or intervening space) between packages inside of the transport vehicle or freight container that prevent commingling of materials in the event of leakage from the packages (See § 177.848(e)(3)).

Whether the frame of the IBC is elevated above the floor of the van, or the 55 gallon drums are on plastic or wooden pallets are not relevant in determining that the requirement for "separation" is being met.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.


Delmer F. Billings
Chief, Standards Division
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 177.848 Segregation of hazardous materials