Interpretation Response #05-0158 ([Georgia Gulf Sulfur] [Mr. Jerry J. Jennett])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Georgia Gulf Sulfur
Individual Name: Mr. Jerry J. Jennett
Location State: GA Country: US
View the Interpretation Document
Response text:
Jul 27, 2005
Mr. Jerry J. Jennett Reference No. 05-0158
President
Georgia Gulf Sulfur
P.O. Box 1165
Valdosta, Georgia 31603-1165
Dear Mr. Jennett:
This responds to your letter dated June 28, 2005, regarding the requirements for marking and placarding a shipment of powdered sulfur in 2000 pound super sacks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Domestically, in accordance with Special Provision 30, in § 172.102 of the HMR, a material described as “Sulfur, 9, NA 1350, III”, is not subject to the requirements of the HMR if transported in a non-bulk packaging or if formed to a specific shape (e.g., prills, granules, pellets, pastilles, or flakes).
A CLASS 9 placard is not required in domestic transportation for a Class 9 (Miscellaneous) material. However, a bulk packaging (e.g., 2000 lb. super sack) containing a Class 9 material must display the identification number in accordance with § 172.331. The identification number marking may be displayed on a CLASS 9 placard, an orange panel, or a white square-on-point display configuration (see § 172.332 and
172.504(f)((9)). In addition, for a bulk packaging contained in or on a transport vehicle or a freight container, if the identification number marking is not visible, the transport vehicle or freight container must be marked as required by § 172.332 of each side and each end with the identification number marking for that material (see § 172.331(c)).
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.504, 172.516