# FISC ATACHUB — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 02-0209
- **title:** FISC ATACHUB — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2002-11-08
- **effective on:** Not available
- **summary:** 02-0209 response to FISC ATACHUB concerning 173.150, 173.29.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0209.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0209.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0209
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020209.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S.Department
NOV - 8. 2002
Washington, D.C
Research and
Special Programs
Administration
Ms. Libby Bishop
FISC ATAC HUB
Ref. No. 02-0209
406 "B" St, Bldg DP-237
Norfolk, VA 23511
Dear Ms. Bishop:
This. responds to your August 16, 2002 letter requesting clarification on the correct method of
shipping" empty" fuel tanks and fuel pumps by commercial motor vehicle under the Hazardous.
Materials Regulations (HIMR; 49 CFR Parts 171-180). Specifically, you ask if you may ship your
fuel pumps and tanks that have been drained, but not purged and may contain a trace of JP-5 jet
fuel as a Combustible liquid under § 173.150(D(2): and (1)(3).
You state that you were advised by a DOT representative that you may ship the fuel pumps under
the provisions of § 173.150(f)(2) as non-regulated, and use non-specification boxes for your freight.
You were also advised that you may ship the fuel tanks under § 173.150(f)(3) as "Combustible
liquid, 3, NA 1993" with no label. You request written confirmation from us on the shipping
information provided to you by a DOT représentative.
Section 173.29 requires that an empty packaging containing a residue of a hazardous material be
offered for transportation and transported in the same manner as when it previously contained a
greater quantity of that hazardous material, unless it has been sufficiently cleaned of residue and
purged of vapors to remove any potential hazard. You state in your letter that your fuel pumps and
tanks may contain a trace of JP-5 jet fuel; therefore, they must be shipped in the same manner as
when they previously contained JP-5 jet fuel. However, if the JP-5 jet fuel has a flash point at or
above 100 degrees farenheight and does not meet the definition of any other hazard class, it may be
reclassed as a Combustible liquid and shipped by highway or rail according to provisions specified
in § 173.150(f).
I hope this answers your inquiry.
Sincerely,
Debo Filgo
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.150
020209
173.29

<<<PAGE 2>>>

08/16/02
16:10 FAX 4445972
ATAC HUB FISC NORVA
4002
Boothe
Mr. Edward Mazzullo
USDOT/RSPA
Dir, Office of Hazardous Material Standard
3173.150
DHM) 10
Washington, DC 20590-0001
$173.29
Empry
Deax sir:
02-0209
I spoke with a representative of DOT ou some matters concerning the movement of trace amounts o
IAZMAT in CONUS over the road by commercial carrier for the US Government. He was very helpful ir
anks are crated and nailed very secely and the pumps are wrapped and capped off so as not to leak. Th
your help would be appreciated in moving them to be repaired and returned to airbases for reuse in a timely
aner packaging is done so as to prevent a leak. These parts are critical to the mission of the US NAVY an
manner. Please FAX us an official letter from your office concerning this mattex.
Thank you,
LIBBY BISHOP
FISC ATAC HUB
TRAFFIC MANAGER
406 "B" ST BLDG SP-237
NORFOLK VA 23511
757-444-5972 FAX
757-444-2520 EXT 13 voice
Libby_S_Bishop@nor.fisc.navy.mil
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