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Interpretation Response #18-0009

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

Interpretation Response Details

Response Publish Date: 05-31-2018
Company Name: The Chemours Company    Individual Name: Randolph Martin
Location state: DE    Country: US

View the Interpretation Document

Response text:

May 31, 2018

Randolph Martin
The Chemours Company
1007 Market Street, Room 2024
Wilmington, DE 19899

Reference No. 18-0009

Dear Mr. Martin:

This letter is in response to your January 11, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to bulk packaging requirements for "UN1689 Sodium cyanide, solid, 6.1, Packing Group (PG) I" and "UN3414 Sodium cyanide solution, 6.1, PG III."

We have paraphrased and answered your questions as follows:

Q1. You ask whether "UN1689 Sodium cyanide, solid, 6.1, PG I" is authorized for transport in non-DOT specification cargo tank motor vehicles (CTMV).

A1. The answer is no. Section 172.102(c)(3), Special Provision B69 authorizes several non-specification packagings for "UN1689 Sodium cyanide, solid, 6.1, PG I." It is the opinion of this Office that a non-specification CTMV is not an authorized packaging. Please note that alternate packaging methods for this material, such as a non-specification CTMV, may be authorized under the terms of an approval (see § 172.102(c)(3), Special Provision B77).

Q2. You ask whether "UN3414 Sodium cyanide solution, 6.1, PG III" is authorized for transport in a non-DOT specification CTMV.

A2. The answer is yes. Section 173.241(b) authorizes non-DOT specification CTMVs suitable for transport of liquids for "UN3414 Sodium cyanide solution, 6.1, PG III."

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

Regulation Sections

Section Subject
§ 173.241 Bulk packagings for certain low hazard liquid and solid materials