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Interpretation Response #98-0365 ([Western Farm Service] [Mr. Warren O. Purdy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Western Farm Service

Individual Name: Mr. Warren O. Purdy

Location State: CA Country: US

View the Interpretation Document

Response text:

DEC 1, 2000


Mr. Warren O. Purdy                          Reference No. 98-0365

Senior Division Agronomist

Western Farm Service

509 West Weber Avenue, Suite 201

Stockton, CA 95203

Dear Mr. Purdy:

This is in response to your letters and telephone conversations with me and Ms. Eileen Edmonson of my staff concerning whether the shipment of a fertilizer, identified as "Ammonium nitrate, 5.1, UN 1942, PO III," "Potassium nitrate, 5.1, UN 1486, PO III," or "Sodium nitrate, 5.1, UN 1498, PO III," in a rear-end loaded freight container is authorized under 49 CFR 173.240. We apologize for the delay in response and any misunderstanding or inconvenience this may have caused.

Specifically, you asked whether your 24 foot, rear-end loaded freight container would satisfy the requirement of a sift-proof container. You state that dunnage is placed across the rear end of the freight container, forming a rear wall. The freight container is then lined on the bottom and all sides, up to a height of 7 feet, with 4-ml thick clear polyethylene. The fertilizer is loaded in loose bulk form, using a troughing conveyor, into the enclosed area. After loading is completed, you stated the plastic liner is secured over the top of the fertilizer, and additional dunnage and liner is . secured over the upper portion of the rear wall to prevent the release of any contents. The package, weighing about 21.5 tons, is transported by vessel from California to Hawaii.

Based upon the information you provided, the answer is yes. Your packaging would satisfy the requirements of a sift-proof, non-DOT specification, closed bulk bin under § 173.240(c).



Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

Regulation Sections

Section Subject
173.240 Bulk packaging for certain low hazard solid materials