Interpretation Response #09-0252
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
December 3, 2009
Mr. Alex Henderson
Ocean Transport Manager
75 Montgomery Street, Suite 301
Jersey City, NJ 07302
Reference No. 09-0252
Dear Mr. Henderson:
This is in response to your October 26, 2009 letter concerning the requirements for segregating hazardous materials on a motor vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask if the HMR prohibit all Division 6.1 (poisonous) materials from being loaded on the same motor vehicle with a Class 3 flammable liquid or only those that are liquid and meet the definition of Packing Group (PG) I, Hazard Zone A, prescribed in § 173.133(a)(2).
The HMR prohibit only those Division 6.1 liquids that meet the definition of a Packing Group (PG) I, Hazard Zone A material from being loaded on the same motor vehicle with a Class 3 flammable liquid. Unless an exception exists elsewhere in the HMR, hazardous materials transported by motor vehicle must be stored, loaded, or transported as specified in the "Segregation Table for Hazardous Materials" (Segregation Table) prescribed in § 177.848(d). The letter "X" appears in the entry on the Segregation Table for liquid, PG I, Hazard Zone A, Division 6.1 materials and Class 3 liquids, which indicates that these materials may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation. However, please note that materials classed as Division 6.1 PG I, Hazard Zone B, C, or D, or PG II or PG III have no restrictions with other hazardous materials, as pointed out in the instructions for using the Segregation Table (see
§ 177.848(e)), but may not be transported on the same vehicle with materials marked as or known to be foodstuffs, feed, or any other edible material intended for consumption by humans or animals. See § 177.841(e)(3).
I hope this satisfies your request.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.133, 177.848(e), 177.841(e)(3)
|§ 177.848||Segregation of hazardous materials|