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Interpretation Response #98-0552

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

Interpretation Response Details

Response Publish Date: 06-15-1998
Company Name: Olin Microelectronic Materials    Individual Name: Ms. Naomi Livingston
Location state: AZ    Country: US

View the Interpretation Document

Response text:

JUN 15, 1998


Ms. Naomi Livingston
Olin Microelectronic Materials
P. O. Box 10099
Mesa, Arizona 85216-0099

Dear Ms. Livingston:

This is in response to your letter regarding methods of achieving separation of hazardous materials, as indicated by the letter "0" in the Segregation and Separation Chart of Hazardous Materials (49 CFR 177.848(e)(3)), on the same transport vehicle in a manner that under conditions normally incident to transportation, commingling would not occur.

This Office evaluates procedures used in complying with this requirement on a case-by-case basis. However, you did not provide any specific information on the hazardous materials involved or the methods your company may use to achieve separation. The requirement for separation or non-adjacent loading is considered satisfied if the packages are separated in such a manner (for example, by using barriers, packages of non-hazardous materials, or intervening space) that their contents would not commingle in the event of leakage under conditions normally incident to transportation.

I hope this satisfies your request.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
§ 177.848 Segregation of hazardous materials