USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #08-0216 ([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:

Company Name: Hawkins, Inc.

Individual Name: Mr. Chris W. Gibson

Location State: MN Country: US

View the Interpretation Document

Response text:

October 7, 2008






Mr. Chris W. Gibson

EHS&R Manager

Hawkins, Inc.

3100 East Hennepin Avenue

Minneapolis, MN 55413

Ref. No.: 08-0216

Dear Mr. Gibson:

This responds to your letter dated August 20, 2008, regarding the segregation requirements of the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). Specifically, you ask if § 177.848(c) applies to the transport of "Hydrochloric Acid, 8, UN 1789, PG II", and an unregulated material (i.e., Ferric Ferro cyanide) that can produce hydrogen cyanide when it comes into contact with acids.

Paragraph (c) of § 177.848 prohibits cyanides and cyanide mixtures or solutions to be stored, loaded or transported in the same transport vehicle with "acids" if a mixture of the materials would generate hydrogen cyanide. Further, Division 4.2 materials may not be stored, loaded and transported with Class 8 (Corrosive) liquids. This requirement does not address cyanides and cyanide mixtures or solutions transported on the same transport vehicle with unregulated materials. However, § 173.21(e) of the HMR prohibits a material in the same packaging, freight container, or overpack with another material, the mixing of which is likely to cause a dangerous evolution of heat, or flammable or poisonous gases or vapors or to produce corrosive materials. Therefore, the transport of "Hydrochloric Acid, 8, UN 1789, PG II" and an unregulated material (i.e., Ferric Ferro cyanide) that can produce hydrogen cyanide gases or vapors when it comes into contact with acids is forbidden.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

177.848, 173.21

Regulation Sections

Section Subject
173.21 Forbidden materials and packages
177.848 Segregation of hazardous materials