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Interpretation Response #08-0246 ([Tetra Micronutrients] [Ms. Becky Beasley])

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

Interpretation Response Details

Response Publish Date:

Company Name: Tetra Micronutrients

Individual Name: Ms. Becky Beasley

Location State: NE Country: US

View the Interpretation Document

Response text:

October 16, 2008

Ms. Becky Beasley

Traffic Manager

Tetra Micronutrients

71025 569 Avenue

Fairbury, NE 68352

Ref. No. 08-0246

Dear Ms. Beasley:

This responds to your September, 25 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for the HMR requirements applicable to paperwork, packaging, loading, driver training, and transporting a material classed as "Environmentally hazardous substance, solid n.o.s., Class 9, UN 3077, PG III (zinc sulfate)," in 50 and 2,000 pound bags and 25-35 ton bulk loads. In addition, you ask if the CLASS 9 placard is required on the vehicle or packages.

A Class 9 material transported by highway is subject to the shipping paper requirements in Part 172, Subpart C and § 177.817; the packaging requirements in Column 8 of the Hazardous Materials Table (HMT; § 172.101); and the requirements in Part 177, including driver training, loading, unloading, and carriage requirements. A CLASS 9 placard is not required for domestic transportation (see § 172.504(f)(9)). However, each non-bulk package (e.g. 50 pound bag) must be marked with the proper shipping name and identification number as provided by § 172.301 and must have a CLASS 9 label as provided by § 172.400. Bulk packages (e.g., 2,000 pound bag and 25-35 ton bulk load) containing a Class 9 material must be marked with the appropriate identification number displayed on a CLASS 9 placard, an orange panel, or a white-square-on-point display configuration.

You should also note that a hazardous substance is defined in § 171.8 as a material, including its mixtures and solutions, that is listed in Appendix A to § 172.101, and is in a quantity, in one package, that equals or exceeds the reportable quantity (RQ) for the material listed in Appendix A. Zinc sulfate is listed in Appendix A with an RQ of 1,000 pounds. The 50 pound bag you describe may not meet the definition of a hazardous substance as defined in § 171.8, because the amount in each bag does not exceed the RQ for zinc sulfate.

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


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

172.101, 177.817,

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
177.817 Shipping papers