URS Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration FEB 26 2004 Mr. Andrew N. Romach Ref. No. 03-0278 Regulatory Manager URS Corporation 1066 Perimeter Park Drive Morrisville, NC 27560 Dear Mr. Romach: This responds to your November 3, 2003, letter requesting clarification on packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask whether a sift-proof bulk bin may be used as both a bulk package for a Division 4.1 material and a freight container for limited quantity packages of a Class 3 material. Specifically, you ask if it is permissible to ship limited quantity packages of "Flammable liquid, i.o.s. (toluene, xylene), UN 1993, PG IT", each marked with the proper shipping name and UN number and "Ltd. Qty."in a leakproof, siftproof bulk bin containing II" material. otherwise unpackaged "Solids containing flammable liquid, n.o.s.(toluene, xylene), 4.1, UN 3175, PG The answer to your question is no. A freight container that is the bulk packaging for an unpackaged hazardous material may not be used simultaneously as a freight container for the shipping of packaged hazardous material. Such usage is inconsistent with the definition for "bulk packaging" and would result in incongruous quantity descriptions on the shipping paper. Therefore, the limited quantity Class 3 material. material packages must be shipped separately from the package containing the bulk solid Division 4.1 I hope this answers your inquiry. Sincerely, Alum D7. Moza Edward T. Mazzullo Director, Office of Hazardous Materials Standards HIVININ 173,25 030278#

Page 2INFOCNTR Sent: From: To: Nach Purs on or 428 PM Boothe Subject: Cc: INFOCNTR Attn: Arthur- Bulk Bin Question Carolyn_Norris@urscorp.com §173.25 $173:240 DOT interpretation request: Packaging possible I am writing to ask for an interpretation concerning whether it is for a package to be simultaneously a bulk container and a freight 03-0278 container containing a non-bulk package. The hazardous material in bulk is vermiculite damp with a solvent with no free liquid present, flammable liquid, n.o.s. (toluene, xylene), 411, UN3175, PGII. which is classified as: "sift-proof non-DOT specification portable tanks and closed bulk bins required packaging for this material is set out in 49 CFR 173.240 (c): outside of authorized." the bulk contact would be placed on stri his bulk container is a leak-proot a flammable solid placard and also have the UN number 3175 displayed on each of foux sides. The hazardous material in the non-bulk container is the same solvent solvent volume being 1 quart (1 liter)] pląced into contained in glass jars [the largest • 5 gallon metal shipment, with classification: Flammable liquid, n.o.s. (toluene, his hazardous material in this volume qualifies as a limited quantity 3, UN1993, PGII. The required packaging for this material is set out in gallon CFR 173.150 (b) (2) . drums (pails), each pail is much less than 66 This material would be packaged in sturdy metal ! weight. pounds gros: I- Would we be allowed to place the non-bulk limited quantity ta. ety.", into the bulk container with the bulk material? Because limited each marked with the proper shipping name shipments are excepted from placarding, it is not a requirement to freight the presence of the limited quantity shipment on the outside of the container. The container would only be placarded for the bulk material. See suggestion below: 2- How would the DOT basic description for this shipment be written? (toluene, xylene), 4.1, UN3175, PGII 1 bulk bin Solids containing flammable liquid, n.o.s. 1,000 pounds 100 Bulk bin also contains: UN1993, PGII, Itd. Qty. (5gal) drums Flammable liquid, n.o.s. 400 pounds (toluene, xylene), 3, I look forward to receiving a reply to my request for interpretation. Thanks,#