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Interpretation Response #04-0062 ([Vanderbilt Chemical Corporation] [Mr. Joe Curtis])

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

Interpretation Response Details

Response Publish Date:

Company Name: Vanderbilt Chemical Corporation

Individual Name: Mr. Joe Curtis

Location State: KY Country: US

View the Interpretation Document

Response text:

Mar 24, 2004

 

Mr. Joe Curtis   
Environmental Manage                Reference No. 04-0062
Vanderbilt Chemical Corporation
Murray Division
396 Pella Way
Murray, KY 42071

Dear Mr. Curtis:

This is in response to your letter dated March 10, 2004 regarding the definition of a bulk packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the statement “...in which hazardous materials are loaded with no intermediate form of containment...” found in § 171.8 under the definition of a bulk packaging precludes you from transporting a material classed as “Toxic solid; organic, n.o.s. (zinc dimethyldithiocarbamate), 6.1, UN2811, PG I” in a “11HH2/X” intermediate bulk container (IBC) if the hazardous material is pre-packaged in small, nonspecification paper bags.

As long as the material is packaged in an authorized bulk packaging the fact that it is pre-packaged in small, non-specification paper bags is not relevant.  Note, however, that the bags must not react dangerously with the material or reduce the integrity of the authorized bulk packaging.  According to Column 7 of the Hazardous Materials Table (HMT; § 172. 101) a material that is classified as “Toxic solid, organic, n.o.s. (zinc dimethyldithiocarbamate), 6.1, UN2811, PG I” is authorized to be packaged in IBCs conforming to the requirements of Special Provision 1037.  According to IB7, an IBC identified with the marking code “l1HH2/X”, which represents a composite IBC with a flexible inner receptacle and a plastic outer packaging that has passed all performance tests at the PG I level, is authorized. 

Therefore, it is our opinion that your packaging configuration is authorized under the HMR.

I hope this satisfies your request.

Sincerely,

 

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.427

Regulation Sections

Section Subject
173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)