{"operation":"document","citation":"02-0113","title":"ISK Magnetics, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-05-21","effective_on":null,"summary":"02-0113 response to ISK Magnetics, Inc. concerning 177.838.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0113.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0113.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0113","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020113.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nMAY 2 1 2002\nMs. Mana House\nRef. No. 02-0113\nCustomer Service Manager\nISK Magnetics, Inc.\n600 Montgomery Street, 38'h Floor\nSan Francisco, CA 94111\nDear Ms. House:\nThis responds to your April 5, 2002 letter requesting clarification on § 177.838(a) of the\nHazardous Materials Regulations (HMR; 49 CFR Parts. 171-180). Specifically, you ask if\n§ 177.838(a) authorizes you to ship your Division 4.2 material on a flat-bed truck or on a soft-side\ntrailer, and how to load the material onto these types of vehicles.\nYour understanding of §177.838(a) is correct. All of the hazardous material must be contained\nentirely within the body of the motor vehicle and be covered by a tarpaulin or other suitable means,\nand, if the motor vehicle has a tailboard or tailgate, it must be closed and secured in place during\ntransportation. In addition, shipment in water-tight bulk containers need not be covered by a\ntarpaulin or other means. The use of a flat-bed truck or soft-sided trailer is authorized provided\nthe hazardous material is completely contained within the body of the motor vehicle, e.g., the\nmaterial does not extend beyond the vertical planes projected from the outer edges of the transport\nvehicle, and, is completely covered by a tarpaulin if using a flat-bed truck. In addition to loading\nguidance provided in § 177.838 of the HMR, procedures for blocking and bracing the material on\nthe truck is covered in more detail under the Federal Motor Carrier Safety Regulations contained\nin 49 CFR Parts 390-397.\nT hope this answers your inquiry.\nSincerely,\nDen HaSills\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n177.838\nHINANIN\n020113\n\n<<<PAGE 2>>>\n\nISK MAGNETICS, INC.\nSan Francisco, California\n600 Monrgomery Street, 38th Floor\nBoothe\nS.A. 9411\n$177.838\nlephone 415.249.47\nHighway\nISKMAGNETICS\nApril 5, 2002\nMr. Edward Mazzullo\nDirector, Office of Hazardous Materials Standards\nUSDOT / RSPA (DHM-10)\n400 7* Street SW\nWashington, D.C. 20590 - 0001\nDear Mr. Mazzulio:\nCan you piease provide us with a written interpretation of Section 177.838 in the\n49CFR: (a) Lading within body...?: Does this mean that as long as the material\nis not coming off the edge of the truck, the transportation method is acceptable to\nthe DOT?.\n*:J9 ;00M2G\nISK ships Magnetic Iron Oxide in 1H2 drums [Self-heating solid, inorganic\nn.o.s., (ferroso ferric oxide), 4.2 UN3190]. This material has always been\nshipped in a van-type trailer.\nAccording to sectior: 177.838, it seems this material can be shipped on, for\nthere a rule on how the material should be secured to the flat-bed?\nexample, a flat-bed truck as long as the drums are covered by a tarp? If ok, is\nAlso, can this material be shipped in a \"soft-side\" trailer? Is there also a rule on\nhow to secure the material on this type of trailer?\nThank you for your assistance.\nBest regards,\nMs. Mana House\nCustomer Service Manager\nCo: Cameron - Hazardous Materials Information Center (202) 366-3012","truncated":false,"body_characters":3079}