Interpretation Response #20-0045

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

Interpretation Response Details

Response Publish Date: 10/15/2020

Company Name: ICL Americas

Individual Name: Gregory Phillips

Location State: MO Country: US

View the Interpretation Document

Response text:

October 15, 2020

Mr. Gregory S. Phillips
Senior Regulatory Affairs Manager - Americas
ICL Americas
622 Emerson Rd.
Suite 500
St. Louis, MO  63141

Reference No. 20-0045

Dear Mr. Phillips:

This is in response to your May 26, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lading density and the maximum weight of lading when loading cargo tanks. Specifically, you ask whether a previous Letter of Interpretation (LOI) issued under Reference No. 96-0182 on September 25, 1996, remains valid.

The answer is yes. As stated in the LOI, a hazardous material with a density which exceeds the maximum lading density for the cargo tank indicated on the name plate may be loaded in to a cargo tank as long as the maximum weight of the lading marked on the specification plate is not exceeded. See § 173.24b(d)(2).

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.24b(d)(2)

Regulation Sections