Interpretation Response #24-0046
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Entegris
Individual Name: Shelley Stampfler
Location State: CT Country: US
View the Interpretation Document
Response text:
September 25, 2024
Shelley Stampfler
Logistics Specialist IV
Entegris
7 Commerce Drive
Danbury, CT 06810
Reference No. 24-0046
Dear Ms. Stampfler:
This letter is in response to your May 22, 2024, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code applicable to the segregation of hazardous materials when transported by vessel. Your questions are paraphrased and answered below.
Q1: You ask whether a Division 2.3 gas poisonous by inhalation (with a subsidiary hazard of Class 8 corrosive) and a Division 2.3 gas poisonous by inhalation (with a subsidiary hazard of Division 2.1 flammable gas) require segregation.
A1: The answer is no, provided the Division 2.3 gases poisonous by inhalation are shipped in accordance with the applicable provisions detailed in § 176.83 and section 7.2.6.1 of the IMDG Code. Multiple Division 2.3 gases poisonous by inhalation may be stowed in the same container for vessel transportation without regard to the subsidiary hazards, provided the different gases are not capable of reacting dangerously with each other and causing any of the conditions listed in § 176.83(a)(8) or section 7.2.6.1 of the IMDG Code. Specifically, as provided in § 176.83(a)(8) and section 7.2.6.1 of the IMDG Code, and notwithstanding the requirements of paragraphs (a)(6) and (a)(7) and sections 7.2.3.3 and 7.2.3.4 of the IMDG Code, hazardous materials of the same class may be stowed together without regard to segregation required by secondary hazards (subsidiary risk label(s)), provided the substances do not react dangerously with each other and cause: (1) a combustion and/or evolution of considerable heat; (2) an evolution of flammable, toxic, or asphyxiant gases; (3) the formation of corrosive substances; or (4) the formation of unstable substances.
Q2: You ask whether a Division 2.3 gas poisonous by inhalation (with a subsidiary hazard of Class 8 corrosive) and a Division 2.3 gas poisonous by inhalation (with a subsidiary hazard of Division 2.1 flammable gas) can be stowed in the same transport unit when transported by vessel.
A2: The answer is yes, as provided in answer A1.
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
176.83, 176.83(a)(8)
Regulation Sections
| Section | Subject |
|---|---|
| 176.83 | Segregation |