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Interpretation Response #99-0306

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

Interpretation Response Details

Response Publish Date: 12-02-1999
Company Name: California Highway Patrol<    Individual Name: Mr. George Barber
Location state: CA    Country: US

View the Interpretation Document

Response text:

December 2, 1999


Mr. George Barber                 Ref No. 99-0306
California Highway Patrol
2072 Third Street
Oroville, CA 95965

Dear Mr. Barber:

This is in response to your letter dated November 5, 1999, regarding segregation requirements under § 177.848(e)(3) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if lab packs containing Division 4.1 and Class 8 liquids may be considered a truckload and therefore loaded above or adjacent to one another when offered by different shippers and transported by a single carrier.

The answer is no.  Section 177.848(e)(3) states that Class 8 liquids may not be loaded above or adjacent to Class 4 or Class 5 materials.  Section 177.848(e)(3) also states that 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 term truckload as used in this section means a shipment of hazardous materials loaded into a transport vehicle by a single shipper.  Shipments of hazardous materials offered to a carrier by different shippers and loaded into a transport vehicle are not considered to be a truckload.  Therefore, a carrier that receives Class 4 and Class 8 materials from different shippers must segregate the materials in accordance with § 177.848(c)(3).

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 177.848 Segregation of hazardous materials