Interpretation Response #23-0002
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: TOTE Maritime Alaska
Individual Name: Timothy Diaz
Location State: WA Country: US
View the Interpretation Document
Response text:
March 27, 2023
Timothy Diaz
TOTE Maritime Alaska
500 East Alexander Ave
Tacoma, WA 98421
Reference No. 23-0002
Dear Mr. Diaz:
This letter is in response to your January 5, 2023, email, and subsequent phone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to segregation requirements specified in footnote 2 to the table in § 176.84(b). Specifically, you have packages of hazardous materials prepared to be shipped in the same container—i.e., cargo transport unit (CTU)—and you seek confirmation that these hazardous materials may be contained in the same CTU without regard to segregation requirements based on footnote 2.
The hazardous materials to be shipped and their quantities are provided follows:
| UN ID / PSN / Class / Packing Group | Quantity |
|---|---|
| "UN3028, Batteries, dry, containing potassium hydroxide solid, electric storage, 8" | 1 x 600 lbs. |
| "UN3028, Batteries, dry, containing potassium hydroxide solid, electric storage, 8" | 1 x 300 lbs. |
| "UN1719, Caustic alkali liquids, n.o.s. (Sodium hydroxide, Potassium hydroxide), 8, PG II" | 1 x 27 gal. |
| "UN1830, Sulfuric acid with more than 51 percent acid, 8, PG I" | 1 x 10 lbs. |
| "UN3264, Corrosive liquid, acidic, inorganic, n.o.s (Acetic acid, Nitric acid), 8, PG II" | 1 x 57 lbs. |
Based on the information provided, the "UN3028" and "UN1719" materials exceed the quantity limitation as prescribed in § 176.84(b) table of provisions, footnote 2. The footnote specifies that Class 8 (corrosive) materials in PG II or III that otherwise are required to be segregated from one another may be transported in the same CTU—whether in the same packaging or not—provided the substances do not react dangerously with each other to cause combustion and/or evolution of considerable heat, or of flammable, toxic, or asphyxiant gases, or the formation of corrosive or unstable substances. Further, each package may not contain more than 30 L (7.8 gallons) for liquids or 30 kg (66 lbs.) for solids. Therefore, those packages listed above that exceed the quantity limits are subject to segregation requirements and may not be shipped in the same CTU.
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
176.84(b)