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Interpretation Response #05-0138


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

Interpretation Response Details

Response Publish Date: 08-09-2005
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
§ 173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)