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Interpretation Response #07-0195 ([CDM Technologies, Inc.] [Mr. Boone Pendergrast])

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

Interpretation Response Details

Response Publish Date:

Company Name: CDM Technologies, Inc.

Individual Name: Mr. Boone Pendergrast

Location State: CA Country: US

View the Interpretation Document

Response text:

Nov 27, 2007

Mr. Boone Pendergrast

CDM Technologies, Inc.

2975 McMillian Street, Suite 272

San Luis Obispo, CA 93401

Ref. No.: 07-0195

Dear Mr. Pendergrast:

This is in response to your October 10, 2007, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to vessel stowage.  Specifically, you request clarification of § 176.83 for the segregation of incompatible containers on board container ships.

In your letter, you describe a scenario in which one container is stowed on deck and another container is stowed below deck in a closed versus closed situation and the incompatible containers are required to be segregated longitudinally by an intervening complete compartment or hold.  It is your understanding that horizontal segregation is not required provided the containers are not stowed in the same vertical line and separated by a fire and liquid resistant bulkhead.

Your understanding is correct.  The fore and aft segregation requirements need only be applied to incompatible containers when they are both on deck or when they are both under deck, unless otherwise stated.

I hope this information is helpful.  Please contact us if you require additional assistance.

Sincerely,

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

176.83

Regulation Sections

Section Subject
176.83 Segregation