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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 #05-0114 ([HazMat Environmental Group, Inc.] [Ms. Colleen A. Orth])

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

Interpretation Response Details

Response Publish Date:

Company Name: HazMat Environmental Group, Inc.

Individual Name: Ms. Colleen A. Orth

Location State: NY Country: US

View the Interpretation Document

Response text:

Jul 27, 2005


Ms. Colleen A. Orth                     Reference No. 05-0114

Compliance Officer

HazMat Environmental Group, Inc.

New Village Industrial Park

60 Commerce Drive

Buffalo, New York 14218-1040

Dear Ms. Orth:

This responds to your April 27, 2005 letter requesting clarification on "closed bulk bins" under § 173.240 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a box van trailer is a "closed bulk bin." You also ask about marking requirements for the bulk packaging.

Section 173.240 authorizes the transportation of certain low hazard solid materials in non-DOT specification sift-proof closed bulk bins. In order to be considered sift-proof; the completed package may not permit the escape of any of the hazardous material contained therein. A "closed bulk bin" is a type of bulk packaging other than a portable tank, cargo tank, tank car and multi-unit tank car. It is the shipper"s responsibility to ensure that the packaging provides sift-proof containment at the time of shipment and will continue to provide that containment until the package reaches its final destination. It is the opinion of this Office that a box van trailer is a "closed bulk bin" if the provisions of § 173.240 requiring sift-proof containment are met.

In addition to being sift-proof and closed, the package must also meet general packaging provisions of § 173.24 and I 73.24b. The bins are also subject to the requirements of the special provisions contained in Column 7 of the Hazardous Materials Table (HMT; 172.101), as applicable to the material being transported.

If the Class 9 material is packaged in a non-specification sift-proof closed bulk bin in accordance with § 173.240(c), the marking requirements in § 172.302, 172.33 1 and 172.332 apply. Specifically, the bulk container must be marked with the appropriate 4-digit UN identification number in the prescribed format. A Class 9 placard is not required for domestic transportation.

I hope this answers your inquiry.



John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.240 Bulk packaging for certain low hazard solid materials