United Parcel Service — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department 400 Seventh Street. S W Washington, D.C. 20590 Research and NOV 2 | 2000 pecial Program dministratio Mr. Samuel S. Elkind Ref. No. 00-0321 Corporate Hazardous Materials Compliance Manager United Parcel Service 8203 National Turnpike Louisville, KY 40214 Dear Mr. Elkind: This is in response to your letter of November 14, 2000 concerning use of packages of non- hazardous materials to secure packages of hazardous materials in a motor vehicle. Within the Hazardous Materials Regulations (Title 49, Code of Federal Regulations, Parts 171- 180), 49 CFR 177.834(a) requires that packages of hazardous materials be secured against movement within a motor vehicle. This requirement is intended to prevent damage to packages due to shifting or falling under conditions normally incident to transportation: You are correct in your understanding that other packages may be used to secure and brace packages of hazardous materials. Specific means for securement of packages are not specified in the regulations; any means of securement which ensures that the packages do not shift or fall, including the long-standing industry practice of securing packages with other packages, is acceptable for meeting this performance requirement. Based on the photographs which you submitted to us (copies enclosed), the packages of hazardous materials appear to be adequately secured against movement by other freight in conformance to the requirements of 49 CFR 177.834(a). Use of other packages for securement has been addressed in a number of other letters from this office, one of which is enclosed. This and other letters of clarification are available through our website at http://hazmat.dot.gov or by writing to this office. I trust this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Edward T. Mazzull Director, Office of Hazardous Materials Standards Enclosures#