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Interpretation Response #05-0027 ([Gabriel Chemicals, L.L.C.] [r. Jim McDaniel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Gabriel Chemicals, L.L.C.

Individual Name: r. Jim McDaniel

Location State: LA Country: US

View the Interpretation Document

Response text:

Feb 11, 2005


M                    &nbsp Reference No. 05-0027
Gabriel Chemicals, L.L.C.
1150 Bank One Centre, North Tower
450 Laurel Street
Baton Rouge, LA 70801

Dear Mr. McDaniel:

This is in response to your February 3, 2005 letter and telephone conversation with Arthur Pollack of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if, when the requirements in § 174.63 are met, chiorosulfonic acid may be transported by rail in an IM portable tank.

The answer is yes. However, portable tanks, IM portable tanks, IBC5, cargo tanks, and multi-unit tank car tanks may not be transported in container-on-flatcar (COFC) or trailer-on-flatcar (TOFC) service except when transported in accordance with § 174.63 or unless approved for transportation by the Associate Administrator for Safety, Federal Rail Administration (FRA) . Chlorosulfonic acid may not be transported in accordance with § 174.63(c) and therefore, must be transported under paragraph (b) or approved by the Associate Administrator for Safety, FRA.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



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


Regulation Sections

Section Subject
174.63 Portable tanks, IM portable tanks, IBCs, Large Packagings, cargo tanks, and multi-unit tank car tanks