Interpretation Response #08-0220 ([URS Corporation] [Ms. Erin N. Jarman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: URS Corporation
Individual Name: Ms. Erin N. Jarman
Location State: NC Country: US
View the Interpretation Document
Response text:
May 14, 2009
Ms. Erin N. Jarman
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560
Ref. No: 08-0220
Dear Ms. Jarman:
This is in response to your request for a clarification of the requirements concerning combustible liquids contained in a bulk packaging under §173.150(f)(3) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for confirmation that combustible liquids in bulk quantities are not required to be offered for transportation in a UN standard or DOT specification packaging. I apologize for the delay in responding and any inconvenience it may have caused.
Your understanding is correct for shipments by highway or rail. Under § 173.150(f)(3), a combustible liquid that is in a bulk packaging (including a combustible liquid that is a hazardous substance, a hazardous waste, or a marine pollutant) is not subject to the requirements of the HMR except those listed in § 173.150(f)(3)(i) through (x). Paragraph (f)(3) provides, among other things, that a combustible liquid in a bulk packaging is not subject to the specification packaging provisions contained in the HMR. Therefore, a bulk non-specification packaging must meet only those requirements in Subpart B, and the various sections listed in §173.150(f)(3)(i) through (x) applicable to non-specification packagings, and not those specific to UN standard or DOT specification packagings.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.150(f)(3)
Regulation Sections
| Section | Subject |
|---|---|
| 173.150 | Exceptions for Class 3 (flammable and combustible liquids) |