Interpretation Response #08-0143 ([Hawkins, Inc.] [Mr. Chris W. Gibson])

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

Interpretation Response Details

Response Publish Date: 08/07/2008

Company Name: Hawkins, Inc.

Individual Name: Mr. Chris W. Gibson

Location State: MN Country: US

View the Interpretation Document

Response text:

August 7, 2008

Mr. Chris W. Gibson

EHS&R Manager

Hawkins, Inc.

3100 East Hennepin Avenue

Minneapolis, MN 55413

Ref. No.: 08-0143

Dear Mr. Gibson:

This responds to your letter dated May 21, 2008, regarding the segregation requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to various chemicals transported in the same motor vehicle. You did not provide any diagrams or photographs or specific information of the location or configuration of the packages on the transport vehicle.

Your company was cited with a violation of the segregation requirements in §177.848; the citation stated that a material described as "Chlorine, 2.3, 8, Zone B, UN 1017" was prohibited from being loaded on the same transport vehicle with Class 5.1 (oxidizing) and Class 8 (corrosive) materials. You asked whether this citation is consistent with the requirements of §177.848.

Hazardous materials may not be loaded, transported, or stored together, except as specified in the "Segregation Table" in §177.848(d). As indicated by the letter "O" in the table, Division 2.3 (poisonous gas, hazard zone B), Class 8 (corrosive) liquid and Division 5.1 (oxidizing) materials may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that, in the event of leakage from packages under conditions normally incident to transportation, commingling of hazardous materials would not occur.

The hazardous materials mentioned above are not prohibited from being transported in the same transport vehicle. The provisions for separation can be met by placing barriers (i.e., impediments, obstructions, dividers, packages of non-hazardous materials, or intervening space) between packages inside of the transport vehicle that prevent commingling of materials in the event of leakage from the packages. Regardless of the methods of separation used, Class 8 (corrosive) liquids may not be loaded above or adjacent to Class 4 (flammable solid) or Class 5 (oxidizing) materials; however, shippers may load truckload shipments of such materials together when it is known that the mixture would not cause a fire or a dangerous evolution of heat or gas

(see §177.848(e)(3)).

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.

Sincerely,

Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

177.848

Regulation Sections