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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 #13-0173 ([KIK Custom Products - Classic Division] [Ms. Stacey Gorka])

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

Interpretation Response Details

Response Publish Date:

Company Name: KIK Custom Products - Classic Division

Individual Name: Ms. Stacey Gorka

Location State: FL Country: US

View the Interpretation Document

Response text:

November 1, 2013

Ms. Stacey Gorka
Transportation Manager
KIK Custom Products – Classic Division
909 Magnolia Ave.
Auburndale, FL 33823

Ref. No.: 13-0173

Dear Ms. Gorka:

This is in response to your August 20, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to highway segregation requirements.  You state that your company offers for transportation by highway a bleach solution which you have classified as a corrosive material UN 1791, hypochlorite solution in packing group (PG) III in various packaging configurations, and that the product is always offered as a limited quantity.   You further state your company offers for transportation on the same truck, but not in the same package, packages containing a 2-3% ammonia solution which you have deemed as not regulated for transport purposes.   You ask for conformation that it is not a violation of §§ 177.848 or 173.24(e)(4) to offer these two materials for transportation by highway on the same transport vehicle.  

These two commodities may be offered for transportation in the same transport vehicle based on the information provided in your email.  As your shipments only consist of one commodity considered to be a hazardous material under the HMR, no segregation in accordance with § 177.848 is required.  In your incoming email you note that the mixed contents paragraph in § 173.24(e)(4) prohibits hazardous materials from being packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other.  This requirement is not applicable to your situation, as you note in your email that you do not offer the two commodities in question in the same package.

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

177.848, 73.24(e)(4)

Regulation Sections

Section Subject
177.848 Segregation of hazardous materials