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Interpretation Response #05-0138 ([MHF Logistical Solutions] [Mr. Kurt Colborn])

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

Interpretation Response Details

Response Publish Date:

Company Name: MHF Logistical Solutions

Individual Name: Mr. Kurt Colborn

Location State: PA Country: US

View the Interpretation Document

Response text:

Jul 5, 2005

 

Mr. Kurt Colborn                    Reference No. 05-0138
Director, Technical Services
MHF Logistical Solutions
800 Cranberry Woods Drive, Suite 450
Cranberry Township, PA 16066

Dear Mr. Colborn:

This is in response to your June 10, 2005 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you seek concurrence that your Super Load Wrapper™ (SLW) gondola lining system meets the general design requirements of § 173.410.

Based on the information you provided, it is our opinion that a gondola railcar with a SLW lining system would satisfy the general design requirements of § 173.410. In addition, the gondola railcar with the SLW lining system would also qualify as an IP-1 (Industrial packaging) in accordance with § 173.411(b).

I trust this satisfies your request.

Sincerely,

 

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

173.427(b)(4)
173.410

Regulation Sections

Section Subject
173.410 General design requirements
173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)