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Interpretation Response #04-0108


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

Interpretation Response Details

Response Publish Date: 10-12-2004
Company Name: Pacific Asphalt Services Company    Individual Name: Mr. Gordon R. Crawley
Location state: WA    Country: US

View the Interpretation Document


Response text:

Oct 12, 2004

 

Mr. Gordon R. Crawley                 Reference No. 04-0108
Pacific Asphalt Services Company
10501 N. E. 38 Place
Kirkland, WA 98033

Dear Mr. Crawley:

This responds to your March 30, 2004 letter requesting clarification on shipping asphalt under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification on the proper shipping name and authorized packaging for use in the shipment of asphalt.

In your letter, you state that asphalt manufacturers ship asphalt with a flashpoint of
316° C that is loaded into portable tanks at a temperature greater than 100° C for transportation by vessel under the proper shipping description “Elevated temperature material, liquid, n.o.s., 9, NA/UN 3257, III, (Asphalt PG 58-28).”

Your questions are paraphrased and answered as follows:

Q1.      What is the correct shipping name for this asphalt product or other grades of asphalt when transported by vessel?

Al.        For asphalt with a flashpoint at or above 37.8° C offered for transportation or transported by vessel at or above its flashpoint, the shipping description for both domestic and international transportation is “Tars, liquid, 3, UN 1999, III  For domestic transportation, you may elect to use the shipping description “Asphalt, 3, NA 1999, III.”

For asphalt offered for transportation or transported by vessel at or above 100° C and below its flashpoint, the shipping description for both domestic and international transportation is “Elevated temperature liquid, n.o.s., (Asphalt), 9, UN 3257, III.”

Q2.      May a company, individual, or marine carrier load or ship asphalt products in steel containers that are not equipped with pressure relief devices?

A2.      A bulk packaging authorized or used for the transport of elevated temperature materials must conform to § 173.247(g) which indicates that pressure control equipment (pressure relief device) is not required if pressure in the packaging would increase less than 10 percent as a result of heating the lading from the lowest design operating temperature to a temperature likely to be encountered if the packaging were engulfed in a fire. However, when pressure control equipment is required (e.g., if the pressure in the packaging increases greater than 10 percent as a result of heating the lading from the lowest design operating temperature to a temperature likely to be encountered if the packaging were engulfed in a fire), it must prevent rupture of the packaging from heating, including fire engulfment.

I hope this answers your inquiry.

Sincerely,

 

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

172.101, 173.247

Regulation Sections

Section Subject
§ 173.247 Bulk packaging for certain elevated temperature materials