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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.

Sincerely,

 

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

173.240

Regulation Sections

Section Subject
173.240 Bulk packaging for certain low hazard solid materials