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Interpretation Response #05-0248 ([Cognis Corporation] [Ms. Cindy S. Bryant])

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

Interpretation Response Details

Response Publish Date:

Company Name: Cognis Corporation

Individual Name: Ms. Cindy S. Bryant

Location State: OH Country: US

View the Interpretation Document

Response text:

Nov 4, 2005


Ms. Cindy S. Bryant                           Reference No. 05-0248
Transport Regulatory Specialist
Cognis Corporation
5051 Estecreek Drive
Cincinnati, OH 45232-1446

Dear Ms. Bryant:

This responds to your September 27, 2005 letter requesting clarification of applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to loading operations. Specifically, you ask whether the attendance requirements in § 177.834(i) apply when a shipper is filling a cargo tank prior to the carrier’s arrival at the facility to take possession of the shipment for transportation.

The answer is no. The filling of a cargo tank or other bulk packaging by a shipper is regulated as a pre-transportation function under the HMR. Thus, a shipper must comply with applicable HMR requirements concerning compatibility of lading with the packaging, outage and filling limits, securing of valves and closures, venting, and similar provisions. The attendance requirements in § 177.834(i) apply to loading and unloading operations conducted by carrier personnel. Shipper personnel filling a cargo tank prior to a carrier taking possession of the hazardous material for transportation need not comply with the attendance requirements in § 177.834(i).

I trust this satisfies your inquiry.



Susan Gorsky
Acting Director
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
177.834 General requirements