{"operation":"document","citation":"02-0310","title":"Spray Chem Chemical Company, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-04-03","effective_on":null,"summary":"02-0310 response to Spray Chem Chemical Company, Inc. concerning 177.848.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0310.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0310.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0310","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020310.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nResearch and\nof Transportation\n400 Seventh St., S.W\nWashington, D.C. 2059C\npecial Program\nidministratio\nAPR -3 2003\nMr. Clifford L. Jacobson\nSpray Chem Chemical Company, Inc.\nRef. No.: 02-0310\n705 Keenan Court\nDurham, CA 95938\nDear Mr. Clifford:\nThis responds to your letter regarding the proper segregation and separation of a Division 5.1 (oxidizer)\nand a Class 8 (corrosive) liquid under the Hazardous Materials Regulations (HMR; 49 CFR Parts\n171-180). Your questions are paraphrased and answered as follows:\nQ1.\nspecified in § 177.848 of the HMR.\nWhat is the definition of the term \"separation\" in the segregation and separation requirements\nAl.\nThe term \"separation\" as it relates to the segregation of hazardous materials on a transport\nvehicle or freight container is not defined in the HMR. Section 177.848(e)(3) states that\naccordingly during the course of transportation separation may be accomplished by some\nmeans of physical separation, such as non-permeable barriers, non-reactive freight, or non-\nseparated.\ncombustible, non-reactive absorbents between packages of hazardous materials required to be\nQ2.\nYou asked if the following scenario would be considered proper separation?\nA 330 gallon Intermediate Bulk Container (IBC) containing 35% hydrogen\nperoxide (Division 5.1) is loaded onto a van with 55-gallon drums or an IBC\ncontaining Class 8 (corrosive) liquid. The IBC containing the Division 5.1\nfloor and has fork lift cut outs for loading and unloading. The 55-gallon drums\nare elevated above the floor and placed on wooden or plastic pallets.\nA2.\nThe answer is yes. The provisions for separation can be met by placing barriers (i.e.,\nimpediments, obstructions, dividers, packages of non-hazardous materials, or intervening\nspace) between packages inside of the transport vehicle or freight container that prevent\ncommingling of materials in the event of leakage from the packages (See § 177.848(e)(3)).\n020310\n177.848\ntripsiman.\n\n<<<PAGE 2>>>\n\nWhether the frame of the IBC is elevated above the floor of the van, or the 55 gallon drums are on\nmet.\nplastic or wooden pallets are not relevant in determining that the requirement for \"separation\" is being\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nDelmer F. Billings\nChief, Standards Division\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nFROM : SPRAY-CHEM,FAX (916)896-0147\nPHONE NO. : 5308953658\nDec. 842002 18:459M 18:459MP1\nSpray Chem\nEngrum\nChemical Company, Inc.\n/530. 895-3658 Fax 530 896-0147\n.705 Keenan Court, Durham, CA 95938\n311. 848\nwww.spraychem.com\nsegreytion\n-\n52-0310\n' Doc 4, 2002\nEdward Mazzullo\nUS DOT/RSPA \"DHM 10\"\nDirector: Office of Hazardous Materials Standards\n400 7th. Street SW\nWashington DC 20590\nFAX 202 366-3012\nDear Mr. Mazzullo\nI would like a formal interpretation of the following\n1. What is the exact definition of the term \"SEPARATION\"\nThis would be when the term is used in the context of describing the separation required\nbetween an oxidizer class 5.1 and a corrosive liquid.\n2. If an IBC container, for example, a 330 gallon Snyder tote were filled with 35%\nidentical Snyder poly totes that were filled with a corrosive liquid would the following be\nHydrogen Peroxide (class 5.1) and was loaded onto a van with 55 gallon poly drums or :\n• considered proper separation?\nA The BC containers liner is elevated above the floor by the poly structure that houses\nthe liner.. This is basically the frame of the Snyder that has the fork lift cut outs for loading\nand unloading.\nB. The 55 gallon poly drums are elevated above the floor of the van by placement on\nstandard wooden pallets.\nG. The IBC containing the 5.1 oxidizer and the Corrosive liquid IBC's and drums are\nseparated by distance by poly drums or IBC's containing non hazardous material between\nthem and the IBC containing the 5.1 Oxidizer.\n3. Would it make any difference if the pallets were plastic pallets and not wooden?\n4. If the fact that the pallets were wooden (a combustible material) were not considered\nproper separation then would the floor of the van (also wood) be considered not proper..:\nseparation ?\n5. Would the poly frame around the IBC that holds the liner from contact with the wooden\nfoor be considered proper separation from the floor and the poly drums on pallets?\nWould the IBC setting ontop of a plastic pallet be considered separation from the wooden.\nfloor?\n\n<<<PAGE 4>>>\n\nFROM : SPRAY-CHEM, FAX ‹916>896-0147\nPHONE NO. : 5308953658\nDec. 04. 2002 10:46AM F2\nIf not, then is it possible to transport the IBC, containing a 5.1 oxidizer in the same van\nwith liquid corrosives in poly drums or for that matter in the same van with other IBC.\"\ncontainers that contain liquid corrosive material? If so, what would be the specific\nseparation requirement ?\nThank You for your time\nClifford L. Jacobson\n705 Keenan Court\nSpray Chem Corp.\n: Durham, CA 95938","truncated":false,"body_characters":4937}