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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #23-0101

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

Interpretation Response Details

Response Publish Date:

Company Name: NRS Ocean Logistics Ltd.

Individual Name: Ms. Nicole Enright

Location State: TX Country: US

View the Interpretation Document

Response text:

April 16, 2024

Ms. Nicole Enright
General Manager - Americas
NRS Ocean Logistics Ltd.
10077 Grogan's Mill Rd.
Suite 280
The Woodlands, TX  77380

Reference No. 23-0101

Dear Ms. Enright:

This letter is in response to your November 16, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of paraformaldehyde in United Nations (UN) portable tanks built in accordance with the International Maritime Dangerous Goods (IMDG) code instruction T3. Specifically, you ask whether the HMR authorize the portable tank described in your email for the transportation of "UN 2213, Paraformaldehyde, 4.1, PG III."

The answer is yes. The hazardous material description "UN 2213, Paraformaldehyde, 4.1, PG III," is assigned bulk special provisions T1 and TP33 in § 172.101 of the Hazardous Materials Table (HMT). Although special provision T3 is not assigned to "UN 2213, Paraformaldehyde, 4.1, PG III," the HMR authorize the use of a UN portable tank conforming to the alternative tank instructions listed in § 172.102(c)(7)(v). If your new UN portable tank meets the requirements of § 172.102(c)(7)(v), then the new UN portable tank could transport "UN 2213, Paraformaldehyde, 4.1, PG III." In addition, when imported by vessel, and the IMDG Code is utilized, portable tanks with "higher test pressures, greater shell thicknesses, more stringent bottom opening and pressure-relief device arrangements" are authorized. See IMDG Code

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


Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.101, 172.102(c)(7)(v)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.102 Special provisions