Spray Chem Chemical Company, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W Washington, D.C. 2059C pecial Program idministratio APR -3 2003 Mr. Clifford L. Jacobson Spray Chem Chemical Company, Inc. Ref. No.: 02-0310 705 Keenan Court Durham, CA 95938 Dear Mr. Clifford: This responds to your letter regarding the proper segregation and separation of a Division 5.1 (oxidizer) and a Class 8 (corrosive) liquid under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. specified in § 177.848 of the HMR. What is the definition of the term "separation" in the segregation and separation requirements Al. The term "separation" as it relates to the segregation of hazardous materials on a transport vehicle or freight container is not defined in the HMR. Section 177.848(e)(3) states that accordingly during the course of transportation separation may be accomplished by some means of physical separation, such as non-permeable barriers, non-reactive freight, or non- separated. combustible, non-reactive absorbents between packages of hazardous materials required to be Q2. You asked if the following scenario would be considered proper separation? A 330 gallon Intermediate Bulk Container (IBC) containing 35% hydrogen peroxide (Division 5.1) is loaded onto a van with 55-gallon drums or an IBC containing Class 8 (corrosive) liquid. The IBC containing the Division 5.1 floor and has fork lift cut outs for loading and unloading. The 55-gallon drums are elevated above the floor and placed on wooden or plastic pallets. A2. The answer is yes. The provisions for separation can be met by placing barriers (i.e., impediments, obstructions, dividers, packages of non-hazardous materials, or intervening space) between packages inside of the transport vehicle or freight container that prevent commingling of materials in the event of leakage from the packages (See § 177.848(e)(3)). 020310 177.848 tripsiman.#

Page 2Whether the frame of the IBC is elevated above the floor of the van, or the 55 gallon drums are on met. plastic or wooden pallets are not relevant in determining that the requirement for "separation" is being I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Division Office of Hazardous Materials Standards#

Page 3FROM : SPRAY-CHEM,FAX (916)896-0147 PHONE NO. : 5308953658 Dec. 842002 18:459M 18:459MP1 Spray Chem Engrum Chemical Company, Inc. /530. 895-3658 Fax 530 896-0147 .705 Keenan Court, Durham, CA 95938 311. 848 www.spraychem.com segreytion - 52-0310 ' Doc 4, 2002 Edward Mazzullo US DOT/RSPA "DHM 10" Director: Office of Hazardous Materials Standards 400 7th. Street SW Washington DC 20590 FAX 202 366-3012 Dear Mr. Mazzullo I would like a formal interpretation of the following 1. What is the exact definition of the term "SEPARATION" This would be when the term is used in the context of describing the separation required between an oxidizer class 5.1 and a corrosive liquid. 2. If an IBC container, for example, a 330 gallon Snyder tote were filled with 35% identical Snyder poly totes that were filled with a corrosive liquid would the following be Hydrogen Peroxide (class 5.1) and was loaded onto a van with 55 gallon poly drums or : • considered proper separation? A The BC containers liner is elevated above the floor by the poly structure that houses the liner.. This is basically the frame of the Snyder that has the fork lift cut outs for loading and unloading. B. The 55 gallon poly drums are elevated above the floor of the van by placement on standard wooden pallets. G. The IBC containing the 5.1 oxidizer and the Corrosive liquid IBC's and drums are separated by distance by poly drums or IBC's containing non hazardous material between them and the IBC containing the 5.1 Oxidizer. 3. Would it make any difference if the pallets were plastic pallets and not wooden? 4. If the fact that the pallets were wooden (a combustible material) were not considered proper separation then would the floor of the van (also wood) be considered not proper..: separation ? 5. Would the poly frame around the IBC that holds the liner from contact with the wooden foor be considered proper separation from the floor and the poly drums on pallets? Would the IBC setting ontop of a plastic pallet be considered separation from the wooden. floor?#

Page 4FROM : SPRAY-CHEM, FAX ‹916>896-0147 PHONE NO. : 5308953658 Dec. 04. 2002 10:46AM F2 If not, then is it possible to transport the IBC, containing a 5.1 oxidizer in the same van with liquid corrosives in poly drums or for that matter in the same van with other IBC." containers that contain liquid corrosive material? If so, what would be the specific separation requirement ? Thank You for your time Clifford L. Jacobson 705 Keenan Court Spray Chem Corp. : Durham, CA 95938#