Aaron Oil Co., Inc. — Hazardous Materials Safety Interpretation

Page 1FEB 2 2 2001 of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration Ref. No. 01-0047 Ms. Lynn Clemmons Aaron Oil Co., Inc. P.O. Box 2304 Mobile, AL 36652 Dear Ms. Clemmons: This is in response to your request for clarification of authorized packagings for "Solids containing flammable liquid, n.o.s. i quid, OR ta 121-28 Hazardous Materat se matation absorbents, containing negligible amounts of free liquid. in question is petroleum oil contaminated filters and You ask whether a 1.5 cubic yard steel box with a latching lid is authorized as a non-DOT specification closed bulk bin under $ 173.240. Section 173.240 authorizes sift-proof non-DOT specification closed bulk bins. The bulk bins must be enclosed packagings that are strong, firm, durable and constructed so that they are securely closed and contents cannot pass through. The packagings also must meet the applicable requirements in S$ 173.24 and 173.24b. Therefore, "Solids containing flammable liquid, n.o.s." may be transported in your packaging provided it meets I hope this information is helpful. Please contact us if you have additional questions. Sincerely, Hitle z nichel Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 010047#

Page 2UCIntyre $173.24€ • AARON OIL Bulk Packaging COMPANY. INC. 01 - 0047 P. O. BOX 2304 • MOBILE, ALABAMA 36652 • PHONE (334) 479-1616 February 7, 2001 Office of Hazardous Materials Standards U.S. Department of Transportation Research and Special Programs Administration 400 Seventh Street, S.W. Washington, D.C. 20590 Dear Sir or Madam: I would like to request a written interpretation of 49 CFR 173.240 as it pertains to packaging for solids containing flammable liquids. Specifically, my questions are: 1. Does a 1.5 cubic yard steel box with a latching lid meet the description of a non- Is this a suitable container for shipping petroleum oil contaminated filters and DOT specification closed bulk bin? absorbents, containing negligible amounts of free liquid via tractor trailer? These materials are shipped under the DOT description - Solids containing flammable liquids, N.O.S. (petroleum contained absorbent material), 4.1, UN 3175, PGII. My interpretation based on the hazardous materials table and the information in 173.240 and 173.241 is that this is a proper container for the shipment of petroleum oil contaminated filters and absorbents. Please respond in writing as to whether or not this is a correct interpretation. Thank you for your attention to this matter. Sincerely, Apin (lennons Lynn Clemmons Compliance Officer#