Interpretation Response #02-0311 ([CSX Lines, LLC] [Cliff Bartley])

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

Interpretation Response Details

Response Publish Date: 02/26/2003

Company Name: CSX Lines, LLC

Individual Name: Cliff Bartley

Location State: FL Country: US

View the Interpretation Document

Response text:

Feb 26, 2003

Mr. Cliff Bartley                 Reference No. 02-0311
Corporate Manager Hazardous Materials/Maintenance
CSX Lines, LLC
5800-1 William Mills Road
Blount Island
Jacksonville, FL 32226

Dear Mr. Bartley:

This is in response to your November 21, 2002 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers and segregation requirements.  Your questions are paraphrased and addressed as follows:

Q1. Is the flash point required on shipping papers for limited quantities of Class 3 shipments transported by vessel?

A1. Yes.  In accordance with § 172.203(i)(5), the minimum flash point if 61 degrees Celsius or below (in degrees Celsius closed cup) is required as an additional shipping paper entry in association with the basic description for each shipment transported by water.

Q2. If the flash point is required on the shipping papers for limited quantities of Class 3 cargo, is stowage still restricted to the requirements of § 173.305(c)(1) or is stowage negated by § 176.80(b)?

A2. Section 173.305, referenced in your letter, pertains to the charging of cylinders with a mixture of compressed gas and other material, not stowage of Class 3 (flammable liquid) shipments.  Section 176.305(c)(1) provides for stowage in non-ventilated holds of non-bulk packages of Class 3 (flammable liquid) shipments with a flash point above 23 degrees Celsius.  Section 176.80(b) does not affect the applicability of § 173.305, rather it provides an exception from the segregation requirements of hazardous materials in limited quantities when loaded in transport vehicles and freight containers for transportation by vessel.  The definitions of "limited quantity" and "non-bulk packaging" are found in § 171.8.

I hope this information is helpful.  If we can be of further assistance, do not hesitate to contact us.

Sincerely,

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

172.203

Regulation Sections