Interpretation Response #05-0119 ([Department of the Army] [Mr. Alvin Char])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Department of the Army
Individual Name: Mr. Alvin Char
Location State: HI Country: US
View the Interpretation Document
Response text:
Nov 8, 2005
Mr. Alvin Char Reference No. 05-0119
Department of the Army
Headquarters, United States Army Garrison, Hawaii
Schofield Barracks, Hawaii 96857-5000
Dear Mr. Char:
This is in response to your letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of 100 percent methyl bromide liquid. Specifically, you asked whether “Toxic liquids, corrosive, organic, n.o.s. (methyl bromide) inhalation hazard, PG 1, Zone B, 6.1, UN2927 (6.1, 8)” is an appropriate basic description for your material. You also asked whether you must apply for an exemption to transport the methyl bromide liquid in the packagings as described in your letter.
As a member of my staff explained in a telephone conversation to Mr. Gary Akasaki of your staff, methyl bromide is not correctly classified as a Division 6.1 (poisonous/toxic) material and, therefore, UN2927 is not a correct assignment. Methyl bromide meets the defining criteria in § 173.115 for a Division 2.3 (gas poisonous/toxic by inhalation) material. Based on the information contained in your letter, “Methyl bromide, 2.3, UN1062” is the most appropriate basic description and § 173.193 is the correct packaging authorization section for your material; therefore, the packagings, as described in your letter, are not authorized for methyl bromide.
With regard to the use of packagings not authorized under § 173.193, as explained to Mr.
Akasaki, you may wish to apply for an exemption (special permit) through the
Department of Transportation’s Exemptions and Approvals Office at 202/366-4535.
I hope this information is helpful. Please contact this office should you have additional questions.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.22
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |