Heritage Environmental Services — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration Special Programs DEC 3 2003 Mr. David E. Blair 370-E1 Lathron Industrial Driv Teritage Environmental Service Ref No: 03-0198 Olympia, Washington 98512 Dear Mr. Blair: This is in response to your August 7, 2003 e-mail requesting clarification on the segregation requirements under § 177.848(e)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)for Division 2.3, Zone A and Zone B poisonous gases. Specifically, you ask if the absence of any hazard class or division or a blank space in the segregation table indicates that no restrictions apply to the loading, transportation, or storage of these materials. You ask if the HMR imposes any segregation restrictions on the transportation of the following materials shipped on the same transport vehicle: • Phosphine - Division 2.3, Zone A Phosgene - Division 2.3, Zone A • Hydrogen Sulfide - Division 2.3, Zone B Stibine - Division 2.3, Zone A • Germane - Division 2.3, • Zone B Tungsten Hexafluoride - Division 2.3, Zone A • Nitric Oxide - Division 2.3, Zone A • Phosphorus Pentafluoride, compressed - Division 2.3, Zone B Instructions for use of the § 177.848 Segregation Table state that "the absence of any hazard class or division or a blank space in the Table indicates that no restrictions apply" (§ 178.848(e)(1)). In addition, $ 177.848(e)(6) states that segregation appropriate to the subsidiary hazard must be applied when that segregation is more restrictive than that required by the primary hazard. However,S 1/.040e() allow materials of the same hazard class to be transported together without regard to segregation required for any secondary hazard if the materials are not capable of reacting dangerously with each other and causing combustion or dangerous evolution of heat; evolution of flammable, poisonous or asphyxiant gases; or formation of corrosive or unstable materials. Therefore, since the 1.848 030198#

Page 2materials listed above are of the same hazard class (Division 2.3), and not otherwise incompatible, they may be shipped on the same transport vehicle. I hope this satisfies your inquiry. If you need additional assistance, do not hesitate to contact us. Sincerely, Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3INFOCNTR From: To: Sent: dblair@cco.net Thursday, August 07, 2003 12:09 PM Subject: INFOCNTR Webb Information Center Comments/Questions 5177.848 David E. Blair (dblair@cco.net) on Thursday, August 7, 2003 at 12:09:05. is the result of your feedback form. It was submitted by Segregation 03=0798 Email: dblair@cco.net Name: David E. Blair Category: Highway (Sections 177.800 - 177.870) Organization: Heritage Environmental Svcs. WETS Street: 9730-E1 Lathrop Industrial Drive City: Olympia State: Washington Zip Code: 98512 Phone: 360.705.9004 Fax: 360.705.9383 apply." In the segregation chart, there is a blank at the intersection or division or a blank in the Table indicates that no restrictions no restrictions applicable to the loading, transport, of 2.3 Zone A gases with 2.3 Zone B gases. Does this mean that there are gases with 2.3 Zone B gases either on the same transport vehicle or transportation, and/or storage incident to transportation of 2.3 Zone A stored during transportation in the same facility? segregation For instance, are there any restrictions on the transportation and cylinders - transportation of the following compressed gases in DOT specification ho oil min compress sor i or spect frontion Hydrogen Phosphine - 2.3, Zone A Germane - 2.3, Sulfide - 2.3, Zone B Nitric Oxide - 2.3, Zone A Zone B Phosgene Stibine - 2.3, - 2.3, Zone A Tungsten Hexafluoride - 2.3, Zone B Zone A Phosphorus Pentafluoride, compressed - 2.3, Zone B questions. We would like to have a formal letter of interpretation on the above Please send the letter to the address given below.. Thank You for your consideration, David E. Blair#