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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #03-0044 ([Mr. Scott C. Morrison])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Scott C. Morrison

Location State: PA Country: US

View the Interpretation Document

Response text:

June 6, 2003


Mr. Scott C. Morrison                Reference No. 03-0044
2009 South Trillium Drive
Aliquippa, PA 15001

Dear Mr. Morrison:

This in response to your letter concerning the requirement in paragraph 7.c.(4) of Exemption DOT-E-1l537 that prohibits offerors and carriers from loading on the same motor vehicle intermediate bulk containers (IBCs) containing different hazardous materials that, if mixed, would cause an unsafe condition to occur. You asked if the reason for segregating these materials is essentially the same as that prescribed in 49 CFR 173.33(a)(2) and discussed in letter Reference No. 98-0347.

The answer is yes. The Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) contain various requirements covering the loading of hazardous materials that would react dangerously with each other and cause an unsafe condition to occur. For example, see §§ 173 .21 (e) and 173.33(a)(2). As we stated in the referenced letter, because there are so many variables, the parties involved must evaluate the potential risks posed by different materials that are loaded on the same motor vehicle.



Hattie L. Mitchell, Chief
Regulatory Review & Reinvention
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
173.33 Hazardous materials in cargo tank motor vehicles