Interpretation Response #08-0216
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. Chris W. Gibson
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.
Acting Chief, Standards Development
Office of Hazardous Materials Standards
|§ 173.21||Forbidden materials and packages|