Interpretation Response #98-0021 ([Wright Corporation] [Mr. Rick Wells])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Wright Corporation
Individual Name: Mr. Rick Wells
Location State: NC Country: US
View the Interpretation Document
Response text:
JUN 18, 1998
Mr. Rick Wells Ref. No. 98-0021
Shipping Manager
Wright Corporation
P.O. Box 402
Riegelwood, NC 28456
Dear Mr. Wells:
This is in response to your letter of April 10, 1998, requesting clarification on therequirements for securing packages under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided a scenario in which Hexamethylenetetramine, a Division 4.1 (flammable solid) material, is packaged in 2,000-pound flexible intermediate bulk containers (FIBCs), or in fifty pound bags which are stacked together with glue between each layer. The packages are then placed on pallets, with no means of securement to the pallet. Each unit is loaded on the truck touching adjacent units and walls in a staggered configuration with some spaces remaining. The last two units are secured with load locks to prevent them from moving. You requested confirmation that this scenario you present meets the requirements of the HMR.
Section 177.834(g) requires a motor carrier to ensure that packages are secured against movement within a vehicle to prevent shifting or falling under conditions normally incident to transportation. These conditions most often include vehicle starting, stopping, cornering; accident avoidance, and varied road conditions. Units secured to a pallet that is itself not prevented from movement relative to motion of the "transport vehicle, or containers wedged in the nose of the vehicle without rear support do not meet the requirements of § 177.834(g) for being secured against movement within the vehicle. General req~irements which address protection against shifting or falling cargo are found in the Federal Motor Carrier Safety Regulations (FMCSR; 49 CFR Parts 383-399), specifically under §§ 393.100 to 393.106. These requirements allow varied methods of securement, such as blocking with other freight, banding or use of tie-downs or load-locks.
The requirements in § 177.834(g) are met when packages of hazardous materials are secured in a manner that precludes movement within the transport vehicle, e.g., blocking with other freight, use of tie-downs, or toe-boards. The scenario you provided does not meet the requirements of § l77.834(g). We note the packages are not secured to the pallets and that there are void spaces in your configuration which present the possibility of movement. Any movement of packages relative to the transport vehicle would be a violation of the HMR.
I trust this answers your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Senior Transportation Specialist
Office Of Hazardous Material Standards
177.834
Regulation Sections
| Section | Subject |
|---|---|
| 177.834 | General requirements |