Interpretation Response #05-0138
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
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.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 173.427||Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)|