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Interpretation Response #06-0175 ([Hazardous Material Distribution Consultant] [Mr. Randolph Martin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazardous Material Distribution Consultant

Individual Name: Mr. Randolph Martin

Location State: DE Country: US

View the Interpretation Document

Response text:

Sep 8, 2006

 

Mr. Randolph Martin                 Reference No. 06-0175
Hazardous Material Distribution Consultant
DuPont Global Logistics
1007 Market Street, Room D-5100
Wilmington, DE 19898

Dear Mr. Martin:

This responds to your letter concerning Special provision B69 assigned to the proper shipping name “Sodium cyanide, solid, UN 1689” in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1. Special provision B69 reads: “Dry sodium cyanide or potassium cyanide may be shipped in sift-proof weather-resistant covered hopper cars, covered motor vehicles, portable tanks or non- specification bins. Bins must be approved by the Associate Administrator.” Does the phrase “sift-proof weather-resistant” apply to all of the bulk packagings identified in the special provision?

Al. The answer is yes; all bulk packagings authorized by Special provision B69 must be sift proof and weather resistant.

Q2. Are bins the only bulk packaging that requires approval by the Associate Administrator?

A2. The answer is yes; out of the packagings authorized in B69, only bulk bins require approval by the Associate Administrator.

Q3. Does Special provision B69 authorize use of non-specification portable tanks without obtaining an approval from the Associate Administrator?

A3. The answer is yes; approval is not required for non-specification portable tanks authorized by Special provision B69.

I trust this satisfies your request.

Sincerely,

 

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.102(c)(3)
Special Provision B69

Regulation Sections

Section Subject
172.102 Special provisions