Zambelli Internationale Fireworks Mfg. Co. Inc. — Hazardous Materials Safety Interpretation

Page 1= U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 special Programs Research and Administration JUL 24 2002 Mr: Ron Snyder Zambelli Internationale Ref. No. 02-0044 Fireworks Mfg. Co. Inc. Safety Office RD #1 Box 270 A Edinburg, PA 16116 Dear Mr. Snyder: This responds to your letter regarding the requirements in § 177.834 (g) to secure hazardous materials packages against movement when transported by motor vehicle under the Hazardous Materials Regulations (HMR; 49 CER Parts 171-180). You ask whether packages of Fireworks, Division 1.3G, that are overpacked would satisfy the prevention of motion requirements under $ 177.834 (g). In addition, you ask whether the overpack is required to be secured within the motor vehicle. The requirements in § 177.834 (a) and (g) are met when the packages of hazardous materials are secured in a manner that precludes their movement within the transport vehicle, and between the packages themselves, under conditions normally incident to transportation. These conditions most often include vehicle starting, stopping, cornering, accident avoidance, and varied road conditions. If the packages are overpacked, the vehicle. overpack itself must also be secured within the transport Specific methods for securing packages in a motor vehicle are not defined in the HMR. However, general requirements which address protection of shifting cargo 'arrier Safety Regulations (49 CFR Parts 300-399), specificalli are found in the Federal Moto: methods of securement, such as blocking with other freight, under SS 393.100 to 393.106. These requirements allow varied banding or use of tie-downs or load-locks. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hathe 2 mtihell Hattie I. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 202/07/02 12:04 ZAMBELLI FIREWORKS MFG. CO. → 12023663012 NO.286 001 Stevens $177.834 (g) ZAMBELLI INTERNATIONALE FIREWORKS MFG. CO. INC. Loading/Unloading SAFETY OFFICE 02-0044 RD#1 BOX 270 A EDINBURG, PENNA. 16116 TELEPHONE NO. 1-800-797-6235 FAX#.(724) 652-1456 DATE: 02-05-02 TO: MR. EDWARD I. MAŻZULLO DIRECTOR, OFFICE OF HAZ. MAT. STANDARDS FROM: RON SNYDER SUBJECT: INTERPRETATION OF CFR 177.834G WE WOULD LIKE AN INTERPRETATION: OF THIS SECTION REGARDING FIREWORK 1.3G IN PII PACKAGING. IF THE FIREWORKS ARE ALONE WITHOUT EQUIPMENT IN A TRUCK MEETING ALL OTHER REQUIREMENTS, THEN WHAT OTHER SECUREMENT OF THE BOXES IN A TRUCK IS REQUIRED? DO THE BOXES NEED STRAPPED DOWN OR OTHER WISE SECURED INSIDE THE TRUCK? WE FEEL THAT BECAUSE THE FIREWORKS ARE PACKED IN INDIVIDUAL BOXES; AND THEN THESE BOXES ARE PLACED INSIDE ANOTHER BOX THAT THIS WILL MEET THE REQUIREMENTS FOR PREVENTION OF MOTION, BUT WE ARE AFRAID OF BEING WRONG AND WOULD LIKE AN INTERPRETATION OF THIS. IS THE MERE MOTION OF ONE BOX AGAINST ANOTHER A VIOLATION OF THIS LAW?#