{"operation":"document","citation":"03-0146","title":"Department of California Highway Patrol — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-07-18","effective_on":null,"summary":"03-0146 response to Department of California Highway Patrol concerning 177.848.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0146.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0146.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0146","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030146.pdf","body":"<<<PAGE 1>>>\n\n.S. Departmer\nResearch and\nf Transportatior\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nAdministratior\nJUL 18 2003\nOfficer George Barber, CHPO, 10665\nRef. No.: 03-0146\nDepartment of California Highway Patrol\nCalifornia Highway Patrol, Valley Division\n11337 Trade Center Drive\nRancho, Cordova, CA\nDear Officer Barber:\nThis responds to your June 6, 2003 letter regarding the segregation requirements under the Hazardous\nMaterials Regulations (HIMR; 49 CFR Parts 171-180), as they apply to various chemicals transported\nin the same vehicle. You enclosed copies of several photographs of boxes on pallets inside the vehicle.\nWhile performing an inspection on a vehicle transporting hazardous materials classed as Division 6.1\n(poison), PG I, Poison Inhalation Hazard, Zone B; Class 3 (flammable liquid); Class 8 (corrosive);\nDivision 4.1 (flammable solid); Division 4.3 (dangerous when wet); and Division 5.1 (oxidizers), you\ndiscovered that the van was refrigerated and had a metal ribbed floor. The ribs are approximately 1-\ninch wide and 1-inch deep. The ribbed floor allows cold air to circulate around the product to maintain\na constant temperature, and also allows melting ice to drain to the back of the van and out through the\nrear doors. You asked if hazardous materials in boxes on wooden pallets placed on a \"ribbed floor\"\nwould be considered proper separation, sufficient to prevent commingling of liquid chemicals.\nHazardous materials may not be loaded, transported, or stored together, except as specified in the\n\"Segregation Table\" in §177.848(d). The provisions for separation can be met by placing barriers (i.e.,\nimpediments, obstructions, dividers, packages of non-hazardous materials, or intervening space)\nbetween packages inside of the transport vehicle or freight container that prevent commingling of\nmaterials in the event of leakage from the packages. Regardless of the methods of separation used,\nClass 8 (corrosive) liquids may not be loaded above or adjacent to Class 4 (flammable solid) or Class\n5 (oxidizing) materials; except that shippers may load truckload shipments of such materials together\nwhen it is known that the mixture would not cause a fire or a dangerous evolution of heat or gas (see\n§177.848(e)(3)).\nThe hazardous materials mentioned above are not prohibited from being transported in the same\nvehicle. Boxes shrink-wrapped on pallets, separated by intervening space or packages containing non-\nhazardous materials, satisfy the requirement for \"separation.\" Whether the boxes on wooden pallets are\n177,848\n030146\n\n<<<PAGE 2>>>\n\non a \"ribbed floor\" is not relevant in determining that the requirement for \"separation\" is being met. A\nmaterial poisonous by inhalation leaking from a package can emit toxins that permeate or spread\nthroughout areas of a van or transport vehicle, and can be immediately harmful to any persons entering\nthe van or vehicle.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nShoa Doy\nSusan Gorsky k\nOffice of Hazardous Materials Standards\nSenior Transportation Regulations Specialist\n\n<<<PAGE 3>>>\n\nState of California Business, Transportation and Housing Agency\nDEPARTMENT OF CALIFORNIA HIGHWAY PATROL\nGRAY DAVIS, Governor\n11337 Trade Center Drive\nCalifornia Highway Patrol, Valley Division\n(916) 464-2556 EXT 13\nRancho Cordova, CA\n(800) 735-2922 (Voice)\n(800) 735-2929 (TT/TDD)\nEngrum\nJune 6, 2003\n5177-848\nFile No.: 010665\nsegregation\n83-0146\nTo: U.S. Department of Transportation\nResearch and Special Programs Administration\nWashington, DC 20590\n400 Seventh Street S.W.\nFrom: Officer George Barber 10665\n-\ntransported in the same vehicle.\nPlease provide a letter of interpretation on the following issues relating to incompatible chemicals\nWhile performing a vehicle inspection on a vehicle transporting hazardous materials classed as\ndivision 6.1, PGI, Poison Inhalation Hazard Zone B, Class 3, Class 8 liquid, Division 4.1, Division\n4.3, and Division 5.1. I discovered that the vehicle in use was a refrigerated van with a metal\nribbed floor. The ribs were approximately one inch wide and one inch deep. The purpose of the\nribs is two fold. First, the ribs allow the cold air to circulate around the product in transit to\nmaintain a constant temperature. Second, the ribs allow melting ice to drain to the back of the\nvan and out through the rear doors.\nMy questions are as follows:\n(1) In reading previous letters of interpretation, I understand that segregation must be\ncomplished by a non-permeable barrier, absorbent material, or non-reactive freigh\nonsidering the nature of the floor, would a barrier of wood pallets on the top of the ribs b\n(2) Considering the nature of a material poisonous by inhalation, if the material were to leak could\nsufficient to prevent commingling of liquid chemicals?\nthe toxins permeate the open area of the van and react with other chemicals that may leak?\nPOWER\nEATER·","truncated":false,"body_characters":4966}