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Interpretation Response #99-0300

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

Interpretation Response Details

Response Publish Date: 03-17-2000
Company Name: A/C Industrial Service    Individual Name: Mr. Malcolm G. Maxwell
Location state: CA    Country: US

View the Interpretation Document

Response text:

March 17, 2000


Mr. Malcolm G. Maxwell             Ref.  No. 99-0300
Technical Manager
A/C Industrial Service
Marauder Street
Chico, California 95973

Dear Mr. Maxwell:

This is in response to your letter dated October 29, 1999, regarding the proper segregation and separation of Class 8 (corrosive liquid) and Division 4.1 (flammable solid) hazardous wastes in lab packs under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Class 8 liquids and Division 4.1 solids may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that in the event of leakage from packages, commingling of the hazardous materials will not occur.  Class 8 liquids may not be loaded above or adjacent to Class 4 (flammable) materials.  However, shippers may load truckload shipments of such materials together when it is known that the mixture of contents would not cause a fire or a dangerous evolution of heat or gas.

The HMR require that separation must be accomplished by some means of physical separation, such as non-permeable barriers, non-reactive freight, or non-combustible, non-reactive absorbents between packages of hazardous materials required to be separated.  The provisions for separation can be met by placing barriers (i.e., impediments, obstructions, dividers) between packages inside of the transport vehicle that prevent commingling of materials in the event of leakage from the packages (See § 177.848(e)(3)).

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.



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


Regulation Sections

Section Subject
§ 177.848 Segregation of hazardous materials