Interpretation Response #23-0104
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Chevron Phillips Chemical Company LP
Individual Name: Richard Norl Jr.
Location State: TX Country: US
View the Interpretation Document
Response text:
July 15, 2024
Mr. Richard Norl Jr.
Distribution Safety Manager
Chevron Phillips Chemical Company LP
10001 Six Pines Drive
The Woodlands, TX 77380
Reference No. 23-0104
Dear Mr. Norl:
This letter is in response to your December 6, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of combustible liquids in bulk packaging. You state that based on your reading of the provisions in §§ 171.22 and 171.25, it is your understanding that for the export of combustible liquids in bulk packaging by vessel, the placards may be removed or replaced once inside the port area, as those materials are not regulated by the International Maritime Dangerous Goods (IMDG) Code for international transportation. Specifically, you seek clarification of the HMR regarding the domestic transportation of combustible liquids by motor vehicle before being loaded onto a vessel for export—or conversely—combustible liquids that will be imported by vessel and then moved by motor vehicle domestically.
Your understanding of the HMR requirements regarding placarding requirements for the import and export of combustible liquid shipments is incorrect. In accordance with § 171.22(c), a material designated as a hazardous material under the HMR, but which is not subject to the requirements of the IMDG Code, may not be transported in accordance with the IMDG Code and must be transported in accordance with all applicable requirements of the HMR while in the United States.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Eamonn Patrick
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
171.22, 171.25, 171.22(c)