{"operation":"document","citation":"01-0062","title":"General Dynamics — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-06-07","effective_on":null,"summary":"01-0062 response to General Dynamics concerning 176.76.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0062.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0062.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0062","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010062.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nJUN '7 2001\nMr. Bruce F. Porter\nRef. No. 01-0062\nGeneral Dynamics\n•\n116 East Howard Street\nQuincy, MA 02169-8712\nDear Mr. Porter:\nThis responds to your February 27, 2001 letter requesting clarification on certain vessel stowage\nrequirements for portable tanks of gasoline under the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). Essentially your inquiry relates to the required separation distance when stowing a\nportable tank of gasoline on deck relative to possible sources of ignition such as electrical equipment\nand fixtures that are not intrinsically safe or explosion-proof.\nAlthough not explicit, the intent of the regulations with respect to stowage away from sources of ignition\n(see § 176.305(a)) is simply to apply the distance of 3 meters (10 feet) which is included in the\ndefinition for the term \"away from\" in the segregation provisions set forth in\n§ 176.83(c)(2)(ii). Consequently, stowage of a portable tank of gasoline on deck on board a vessel\nshould ensure at least a 3 meter (10 feet) separation from any sources of ignition.\nI hope this answers your inquiry.\nSincerely,\nTransportation Regulations Speciali\nOffice of Hazardous Materials Standards\n010062\n116:14\n\n<<<PAGE 2>>>\n\nFEB.27.2001\n11:33AM\nAMSEA MARINE OPS (617 770 3207)\n0.551\nBoothe\n. P.1\n176.76(0)\nGENERAL DYNAMICS\nVessel\nAmerican Overseas Marine\nPort Captain\nBruce F. Porter\n01-0062\nFebruary 27, 2001\nBFP/01-001\nMr. Edward Mazzullo\nDirector Office of Hazardous Material Standards\nU.S, Department of Transportation\nDHM-10, 400 7' St., S.W.\nResearch and Special Programs Administration\nDear Mr. Mazzullo,\nI am writing to request a formal interpretation of the 49 CFR 176.76 (i) regarding the stowage and\ncarriage aboard our vessels of an IMO 101 Portable Tank loaded with Motor Gasoline, Class 3.1. Our\nvisits to the United States. The main thrust of my question is what is the distance required from non-\nvessels are part of the Military Preposition Ships and aro engaged in international duty, with occasional\nintrinsically safe electrical fixtures when stowing this portable tank on deck?\nit is clear that the phrase \"stowed \"away from' possible sources of ignition\" as stated in 49 CFR 176.76 (i)\nWhile corresponding with one of your specialists and with Mr. Brian Robinson of the U.S. Coast Guard,\nis unclear and open to vague interpretation. I point to the clarity of 46 CPR. 98.30-9 (2) (i) and (ii) (this\nsection has been defined as non-applicable to our case as it refers to transfer of product) and IMDG\nBoth give distinct measurements from possible sources of ignition as pertaining to portable tanks.\n13.1.25.6.2, Aramendment 29-98, relating to carriage of dangerous cargoes with elevated temperatures.\nThe 49 CPR 176.83 section on Segregation has defined \"away from\" as meaning a dangerous cargo, in\nour case a portable tank of gasoline, may be carried on deck \"provided a minimum horizontal separation\ngroup and Mr. Robinson of the USCG as offering the best answer to my question. For the most part, this\nof 3 meters (10 ft.) projected vertically is obtained\". This is the interpretation being referred to by your\ntank would be stowed on deck in the vicinity of containers loaded with drums of lube oils or other material\nand bardware considered non-hazardous. As this section refers to segregation of dangerous, incompatible\ncargoes, I believe a clarification that relates specifically to the carriage of portable tanks and the required\ndistance from electrical fixtures, vertically as well as horizontally, is necessary. As we are to load this\nportable tank in the near future, a timely response would be much appreciated.\nBest regards,\nBruce F. Porter\n116 East Howard Street\nQuincy, MA 02189-8712\nTel 617-376-8483\nbponer@gdamsea.com\nFax 617-770-3207","truncated":false,"body_characters":3899}