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Interpretation Response #11-0061 ([Ventura Transfer Company] [Mr. Jim Cheney])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ventura Transfer Company

Individual Name: Mr. Jim Cheney

Location State: CA Country: US

View the Interpretation Document

Response text:

August 31, 2011

 

 

 

Mr. Jim Cheney

Compliance Manager

Ventura Transfer Company

2418 E. 223rd Street

Long Beach, CA 90810

Reference No.: 11-0061

Dear Mr. Cheney:

This responds to your March 2, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. You present specific scenarios and ask for clarification pertaining to each.

In your letter, you describe a scenario in which a bulk transloading company unloads hazardous materials from rail cars into cargo tank trailers for delivery to end users. You state that you have several satellite rail terminals from which you transfer the hazardous material from rail cars to cargo tank trailers, and that your cargo tank trailers are based at your main terminal. You further state that you reload the cargo tank trailers with the same material that it arrived initially, without requiring the cargo tank to be washed. You then transport the tank trailer with residue only to the satellite terminal. Finally, you load the cargo tank trailer with the same hazardous material as the previous delivery and take it to the end user. You ask whether you are required to provide two separate shipping papers to the driver for the residue shipment from the main terminal to the satellite terminal and another shipping paper for the delivery of product to the customer?

The answer to your question is no. Generally, a package containing a residue of a hazardous material must be transported in the same manner as when it previously held a greater quantity of the material. Therefore, you would only be required to have one shipping paper to describe the material being shipped in both the full cargo tank trailer and the cargo tank trailer containing residue.

I hope this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

172.202, 173.29

Regulation Sections

Section Subject
172.200 Applicability
173.22 Shipper's responsibility
173.29 Empty packagings