Interpretation Response #16-0201
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 20, 2017
Mr. Gregory Perry
EnviroServices & Training Center, LLC
505 Ward Avenue, Suite 202
Honolulu, HI 96814
Reference No. 16-0201
Dear Mr. Perry:
This letter is in response to your December 14, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for lab packs applicable to the segregation requirements exception in § 173.12(e) and the stowage requirements in § 176.83(b). You present a scenario in which a lab pack containing a hydroxide is transported on a cargo vessel with another lab pack that contains an acid. You note that the hydroxide is required to be "separated" from acids according to the vessel stowage codes in Column 10B of the § 172.101 Hazardous Materials Table (HMT). Specifically, you ask whether § 173.12(e), which excepts certain waste materials from segregation requirements in § 176.83(b), also excludes these applicable materials from vessel stowage requirements.
The answer is no. Column 10B of the HMT refers to other requirements for stowage, cargo handling, and segregation for cargo and passenger vessels in § 176.84. Hazardous materials offered for transportation as limited quantities are not subject to the stowage code assigned by Column 10B; however, the same does not apply for items shipped under the lab pack exception in § 173.12(b).
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.12(e), 176.83(b), 172.101, 176.84, 173.12(b)
|§ 176.84||Other requirements for stowage, cargo handling, and segregation for cargo vessels and passenger vessels|