CSX Lines, LLC — Hazardous Materials Safety Interpretation

Page 1... U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration FEB 26 2003 Mr. Cliff Bartley Corporate Manager Hazardous Materials/Maintenance Ref No. 02-0311 CSX Lines, LLC 5800-1 William Mills Road Blount Island Jacksonville, FL 32226 Dear Mr. Bartley: This is in response to your November 21, 2002 letter requesting clarification of the Hazardous requirements. Your questions are paraphrased and addressed as follows: Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers and segregation Q1. Is the flash point required on shipping papers for limited quantities of Class 3 shipments transported by vessel? Al. Yes. In accordance with § 172.203(i)(5), the minimum flash point if 61 degrees Celsius or below (in degrees Celsius closed cup) is required as an additional shipping paper entry in association with the basic description for each shipment transported by water. Q2. If the flash point is required on the shipping papers for limited quantities of Class 3 cargo, is stowage still restricted to the requirements of § 173.305(c)(1) or is stowage negated by § 176.80(b)? A2. Section 173.305, referenced in your letter, pertains to the charging of cylinders with a mixture of compressed gas and other material, not stowage of Class 3 (flammable liquid) shipments. Section 176.305(c)(1) provides for stowage in non-ventilated holds of non-bulk packages of Class 3 (flammable liquid) shipments with a flash point above 23 degrees Celsius. Section 76.80(b) does not affect the applicability of $ 173.305, rather it provides an exception fro le segregation requirements of hazardous materials in limited quantities when loaded i 203 020311 117.#

Page 2transport vehicles and freight containers for transportation by vessel. The definitions of "limited quantity" and "non-bulk packaging" are found in § 171.8. I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3• - LINES Foster Thursday, November 21, 2002 § 172. 203 $176-80 Mr. Edward Mazullo US DOT / RSPA / DHM-10 400 7 Street SW Shipping Tapper Washington, DC 20590 Vessel Subject: Shipping Papers for Limited Quantities 02-0311 Dear Mr. Mazullo: In 49CFR172.203(i)(5), the regulation require that the flash point in degree "C" be any additional segregation specified in this subchapter for transportation by vessel". Under 49CFR173.305(c)(1), the regulations allow class 3 cargos to be stowed below deck in non-ventilated holes if the flash point is above 23C. This leads me to two questions. * If class 3 cargos in limited quantities are exempt from the segregation requirement, is the flash point required on the shipping papers. * If the flash point is required on the shipping papers for "limited quantities" of 49CFR173.305(*c)(1) or is stowage negated by 49CFR176.80(b) class 3 cargo, is stowage still restricted to the requirements of matter. Thank you for taking the time to examine my problem and in providing guidance on this Respectfully yours, Uff bartly liff Bartle Corporate Manager Hazardous Materials/ Maintenance Cb CSX Lines, LLC CSX Lines • 5800-1 William Mills Road'-"Blount Island - jacksonville, FL 32226 * www.esxlines.com#