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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 #14-0016 ([URS Corporation] [Mr. Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

March 20, 2014

Mr. Andrew N. Romach
URS Corportation
1600 Perimeter Drive
Morrisville, NC 27560

Ref No.: 14-0016

Dear Mr. Romach:

This is a response to your January 17, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the applicability of security plans in § 172.800.  Specifically, you ask whether subsidiary hazards should be considered when determining the applicability of the security plan requirements for shippers and carriers.  In your email, you describe a shipment of a large bulk quantity of “UN2920, Corrosive liquid, flammable, n.o.s.,” with a primary hazard of Class 8, packing group II and a subsidiary hazard of Class 3, packing group III.

In accordance with § 172.800(b), each person who offers for transportation or transports a hazardous material in a quantity indicated in paragraphs (b)(1) through (b)(16) must develop and adhere to a security plan.  In § 172.800(b), a “large bulk quantity” refers to a quantity greater than 3,000 kg (6,614 pounds) for solids or 3,000 liters (792 gallons) for liquids and gases in a single packaging.  

In regards to a large bulk quantity of “UN2920, Corrosive liquid, flammable, n.o.s., 8, 3, II,” with a primary hazard of Class 8, packing group II and a subsidiary hazard of Class 3, packing group III, a security plan would not be required, as there are no corresponding applicability in § 172.800(b) for this material.  Unless specified in paragraph (b) of this section, the applicability for security plans refers to the primary hazard of a material or the definition of a hazard class.

I hope this information is helpful.  If you have any more questions, please do not hesitate to contact this office.


Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.800 Purpose and applicability