Interpretation Response #09-0104 ([Compania SudAmericana De Vapores] [Mr. Hector Alvarez])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Compania SudAmericana De Vapores
Individual Name: Mr. Hector Alvarez
Country: US
View the Interpretation Document
Response text:
January 25, 2010
Mr. Hector Alvarez
The CSAV Group
Dangerous Goods & Documentation Department
Compania SudAmericana De Vapores
Sotomayor 50
2362335 Valparaiso
Chile
Ref. No. 09-0104
Dear Mr. Alvarez:
This responds to your letter requesting clarificationan interpretation and guidance on the correct application of the stowage requirement "shade from radiant heat" in the context of containerized cargo on container ships. Specifically, you expressed your understanding indicate that a closed cargo transport unit does not need to be shaded by means of a structural erection or an awning in accordance with §176.63(b) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and Appendix 1 to Chapter 7.1 of the International Maritime Dangerous Goods (IMDG) Code because the cargo transport unit itself provides shade for the packages or material contained therein.
Your understanding is correct. Structural erections or awnings are not required to protect cargo transport units from radiant heat when stowed on the weather deck of a container ship or any other ship type. The requirements contained in §173.63(b) of the HMR and paragraph 7.1.1.13 of the IMDG Code generally apply to packages or articles stowed on the weather deck without any other means of protection from strong sunlight. Nonetheless, due consideration should be given to the heat sensitivity of the contents within the cargo transport unit and, when necessary, stowage locations in the top tier or in outermost row of containers should be avoided.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.63(b)
Regulation Sections
| Section | Subject |
|---|---|
| 173.63 | Packaging exceptions |