Interpretation Response #18-0138
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Ocean Network Express Inc
Individual Name: Drew Tener
Location State: ID Country: US
View the Interpretation Document
Response text:
May 31, 2019
Drew Tener
Supervisor, Special Commodities Export
Ocean Network Express Inc.
950 West Bannock Street, Suite 700
Boise, ID 83702
Reference No. 18-0138
Dear Mr. Tener:
This letter is in response to your November 1, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR, Parts 171-180) applicable to the segregation requirements of the International Maritime Dangerous Goods (IMDG) Code. You present a scenario involving UN1835 and UN1760 and believe both hazardous materials, in the quantities identified below, may be loaded and transported in the same cargo transport unit based on your understanding of the provisions found in section 7.2.6.4 of the IMDG Code. The hazardous materials and segregation requirements (column 16b of the Dangerous Goods List) are as follows:
- "UN1835, Tetramethylammonium hydroxide solution, 8, PG III," two packages containing 25 liters each. Segregation requirements: Stow "separated from" acids.
- "UN1760, Corrosive liquids, n.o.s., 8, PG III," four drums containing 250 liters each. Segregation requirements: None.
The requirements of section 7.2.6.4 of the IMDG Code state, notwithstanding the provisions of 7.2.5, substances of Class 8, packing group II or III, that would otherwise be required to be segregated from one another due to the provisions pertaining to segregation groups as identified by an entry in column 16b of the Dangerous Goods List indicating "away from" or "separated from" "acids" or "away from" or "separated from" "alkalis," may be transported in the same cargo transport unit, whether in the same packaging or not, provided:
1. The substances comply with the provisions of 7.2.6.1;
2. The package does not contain more than 30 liters for liquids or 30 kilograms for solids;
3. The transport document includes the statement required by 5.4.1.5.11.3; and
4. A copy of the test report that verifies that the substances do not react dangerously with each other shall be provided if requested by the competent authority.
Therefore, your understanding of the segregation requirements found in section 7.2.6.4 of the IMDG Code is not correct. Although the segregation requirements "separated from acids" is only applied to UN1835, in order to use the exception provided in section 7.2.6.4, both UN1835 and UN1760 must meet the provisions of section 7.2.6.4. Specifically, the UN1760 packaged in drums must contain no more than 30 liters of material.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division