{"operation":"document","citation":"00-0154","title":"Equistar Chemicals, L.P. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-06-28","effective_on":null,"summary":"00-0154 response to Equistar Chemicals, L.P. concerning 173.243.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0154.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0154.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0154","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000154.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nSpecial Programs\nResearch and\nAdministration\nJUN 2 8 2000\nMs. Diedre J. Devick\nEquistar Chemicals, I.P.\nRef. No. 00-0154\nProcess Research Center\n8935 North Tabler Road\nMorris, IL\n60450\nDear Ms. Devick:\nThis is in response to your letter dated May 17, 2000 concerning\nspecification packaging requirements for combination packagings\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\n4B240 cylinder as an inner metal receptacle for a combination\nSpecifically you ask if you may use a DOT specification\npackaging authorized under § 173.213 (b).\nThe answer is\nan inner receptacle of a combination packaging provided the outer\nyes. A DOT specification cylinder may be used as\npackaging has been successfully tested with the DOT specification\ncylinder or similar packaging as an inner receptacle.\nWe hope this satisfies your request.\nSincerely,\nGale\nL\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standards\n173,213\n000154\n\n<<<PAGE 2>>>\n\nEQUISTAR\nProcess Research Center\nEquistar Chemicals, LP\nMorris, IL 60450\n8935 North Tabler Road\nPhone: 815.942.7011\nBAtt\n8/73.213\nMay 17, 2000\n00 - 0154\nMr. Edward Mazzullo\nUSDOT/RSPA\nOffice of Hazardous Materials Standards\n4007\" Street SW\nWashington, DC 20590\nDear Mr. Mazzullo.\nand was told by a Hazardous Materials Transportation Senior Specialist that I could use the packaging I\nI have a packaging question about a hazardous material I would like to transport. I called the office today\nasked about. However, in order to document the decision in writing, I was told to write you.\nThe material is classified as a \"Self-heating solid, inorganic, n.o.s., 4.2, UN3190, III.\" According to §\n173.213, the authorized inner packagings include glass, plastic and metal receptacles and glass ampoules.\nMay I use a metal cylinder that is not under pressure as a metal receptacle? According to § 171.8, a\nreceptacle \"means a containment vessel for receiving and holding materials, including any means of\nclosing.\" My \"cylinder\" meets this definition and I believe the reason it is not specifically listed as an\nauthorized inner packaging is because cylinders are typically used for gases and liquids, not solids. My\nmaterial is a solid. The \"cylinder\" has a 3-inch diameter with a maximum capacity of 275 ml. It was\npurchased from Aldrich and has DOT-4B240 stamped on it.\nI would greatly appreciate your response on this matter. Please fax me your decision as soon as possible\nand follow-up with a written copy. I thank you in advance for your cooperation. If you have any further\nquestions, please feel free to contact me.\nSincerely,\nRady. Rout\nDeidre J. Devick\nEquistar Chemicals, L.P.\n8935 N. Tabler Road\nProcess Research Center\nMorris, Il 60450\nPhone: (815) 942-7443\nFax:\n(815) 942-7452","truncated":false,"body_characters":2848}