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

Interpretation Response #09-0211 ([ChemStation International] [Mr. Scott Meridith])

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

Interpretation Response Details

Response Publish Date:

Company Name: ChemStation International

Individual Name: Mr. Scott Meridith

Location State: OH Country: US

View the Interpretation Document

Response text:

April 6, 2011




Mr. Scott Meridith

Service Support Coordinator

ChemStation International

3400 Encrete Lane

Dayton, OH 45439

Reference No. 09-0211

Dear Mr. Meridith:

This is in response to your letter concerning Special Permit DOT-SP 12412 issued by the Pipeline and Hazardous Materials Safety Administration. This special permit authorizes its holder to discharge liquid hazardous materials from DOT Specification 57 portable tanks and certain UN standard intermediate bulk containers (IBCs) while the containers remain on the motor vehicle on which they were transported. You ask if two or more materials that may cause an unsafe condition when mixed may be loaded on the same transport vehicle if one material is in a UN 31H2 open-head plastic intermediate bulk container (IBC) and the other is in a UN 1H1 closed-head plastic drum. We apologize for the delay in responding and any inconvenience this may have caused.

Special Permit DOT-SP 12412 authorizes compatible liquid hazardous materials to be placed in and discharged from a UN 31A, 31B, 31N, 31H1, 31H2, or 31HZ1 IBC, or a DOT Specification 57 portable tank without removal from the transport motor vehicle, an operation not normally permitted under the HMR. See § 177.834(h). In accordance with paragraph 8.c of the special permit, "UN 1778, Fluorosilicic acid (i.e., fluosilicic acid), 8 (corrosive), PG II" and "UN 1791, Hypochlorite solutions, 8, PG II or III" contained in separate IBCs may be loaded on the same motor vehicle with two or more materials that could cause an unsafe condition when mixed provided that: (1) no more than two IBCs are transported on the same motor vehicle; (2) each IBC has a capacity that does not exceed 450 gallons; (3) the materials on the vehicle are not unloaded at the same time; and (4) the hazardous materials on the vehicle are used for water treatment only. Otherwise, paragraph 7.c.4 specifically prohibits packages authorized under the special permit from being loaded on the same motor vehicle with two or more materials that would cause an unsafe condition if mixed.

I hope this satisfies your request.


T. Glenn Foster

Chief, Regulatory Review and Reinvention

Standards and Rulemaking Division


Regulation Sections

Section Subject
177.834 General requirements