{"operation":"document","citation":"04-0033","title":"PPG Industries, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-02-24","effective_on":null,"summary":"04-0033 response to PPG Industries, Inc. concerning 173.21.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0033.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0033.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0033","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040033.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nFEB 2:4 2004\nMr. Gordon W. Rousseau\nRef. No. 04-0033\n5448 Solway Drive\nMelbourne Beach, Florida 32951\nDear Mr. Rousseau:\nThis responds to your February 23, 2004 letter on behalf of PPG Industries, Inc., concerning the\ntransportation of calcium hypochlorite, hydrated, UN 2880, under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Specifically, you ask if calcium hypochlorite, hydrated, UN 2880,\ntransported in 300- and 425-lb. fiber drums, is a forbidden material within the meaning of § 173.21 of\nthe HMR.\nThe answer is no. Notwithstanding that the self-accelerated decomposition temperature (SADT) of\ncalcium hypochlorite, hydrated, UN 2880, in the drums is slightly less than 50 °C, the material is not\nforbidden under § 173.21 because the material is not likely to decompose under normal conditions of\ntransport when shipped in accordance with applicable regulatory requirements. Under the HIMR,\ncalcium hypochlorite, hydrated, UN 2880, is not subject to the controlled temperature provisions of\n§ 173.21(f) when transported in the quantities and packagings specified in your letter. All applicable\nHMR requirements for shipping documentation, packaging, marking, labeling, placarding, and stowage\nand segregation must be met. Similarly, calcium hypochlorite, hydrated, UN 2880, is not a prohibited\nmaterial or subject to temperature control requirements under the provisions of the International\nMaritime Dangerous Goods (IMDG) Code. Under both the HMR and the IMDG Code, calcium\nhypochlorite, hydrated, UN 2880, is subject to stowage provisions that require it to be stowed away\nfrom heat.\nI hope this information is helpful. Please let me know if you have questions or require additional\ninformation.\nSincerely,\nEdward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards\n040033\n|73.21\n\n<<<PAGE 2>>>\n\nGorsky\n3173.2/\nGORDON W. ROUSSEAU Fobbidden\nMelbourne Beach, FL 32951\n5448 Solway Drive\nMaterials\nTel. No. 321-951-3220\nFax No. 413-622-7627\n04-0033\nFebruary 23, 2004\nEdward T. Mazzullo, Director\nOffice of Hazardous Materials Standards\nResearch and Special Projects Administration\nWashington, DC 20590\nU.S. Department of Transportation\nRe: Authorized Transportation of Calcium Hypochlorite Hydrated\n(UN2880) Pursuant to 49 C.F.R. Subchapter C\nDear Mr. Mazzullo:\nI am writing on behalf of PPG Industries, Inc. (PPG). As discussed, PPG has long un-\nderstood that the transportation of UN2880 in 300 and 425 lb. fiber drums is authorized under\nthe provisions of 49 C.F.R. Subchapter C. I should be grateful if you would confirm that PPG's\ninterpretation of the relevant regulatory provisions is correct.\nIt has been suggested that even though authorized by the package requirements of the\nIb. drums is nevertheless \"forbidden\" by § 173.21(f) because the SADT of the product in those\nHazardous Materials Table (HIMT), 49 CFR § 172.101, the shipment of UN2880 in 300 and 42:\ndrum sizes is less than 50°C. (IMO documentation indicates that this SADT information was\nknown as far back as 1980. According to information before the IMO and DOT it is clear that\nthe critical temperature of the product in these drums is below 50°C. Information PPG\nin these drums is between 47°C and 50°C.)\npreviously furnished to DOT confirms the earlier IMO information that the SADT of the product\n\n<<<PAGE 3>>>\n\nGermany and Japan to require temperature controls on UN2880. DOT surely would not have\ndone so if the shipment of UN2880 in 300 and 425 lb. drums were forbidden by § 173.21(f).\ndrums is not \"forbidden\" simply because the SADT threshold is below 50°C, and that UN2880 is\nCan you therefore please confirm that the shipment of UN2880 in 300 and 425 Ib. fiber\nnot on account of § 173.21(f) subject to the controlled temperature provisions in 49 C.F.R. or the\nIMDG Code?\nThank you for your assistance.\nVery truly yours,\nGordon W. Rousseau","truncated":false,"body_characters":3996}