U.S. Coast Guard — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W Pipeline and Administration Hazardous Materials Safety OCT 28 2005 Mr. P.A. Cooley, MSTC Ref. No. 05-02:03 End of State RT 238 U.S. Coast Guard Yorktown, VA 23690-5000 Dear Mr. Cooley: This responds to your August 26, 2005 memorandum requesting clarification on the definition of "fore and aft" and "athwarthips" regarding section § 176.83(f)(4) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request the definition of these terms in the context of general container segregation under § 176.83(f) (4). "Fore and aft" and "athwartships" are common nautical terms. In the context of 49 CFR 176.83(f)(4), "fore and aff" means a container space of not less than 6 m (20 feet) long or "athwartships" means a container space of not less than 2.5 m (8 feet) wide when the container is in parallel (bow to stern) with the keel. In the context of the diagram ("separated from". 2 from chapter 7.2 of the International Maritime Dangerous Goods (IMDG) Code) that accompanied your memo, "fore and aft" means one container space in the direction parallel with the keel (bow to stern) and "athwartships" means one container space perpendicular to the keel (port to starboard) when the container is aligned in parallel to the keel. Two closed incompatible containers are permitted to be segregated by one bay and two rows, as described in your memo, because the containers are one container space, 2.5 m (8 feet) apart in the athwartships (port to starboard) direction. I hope this answers your inquiry. Sincerel 18S4 Chief, Standards Development Office of Hazardous Materials 171.8 176-83 (8)(4) 050203#

Page 283/ 6/2005 09:38 757-856-2494 MARINE SAFETY BRANCH PAGE 02/03 Homeland Security U.S. Department of nited State oast Guard Both anna comer Forkot sna VAR 21590-5000 Phone: 757-656-2290 × 2 {171.8 Fax: Email: patricia. a cooley@uscg.mil 316.83(f)4) 3p Aug 2005 16616 MEMORANDUM Segregation/Detinitions 05-0203 From: Attin of: Reply to P. A. COOLEY, MSTC, USCG 3202 To: OFFICE OF HAZARDOUS MATERIALS SAFETY Subj: GUIDANCE REGARDING "FORE AND AFT" AND "ATHWARTSHIPS" IN REFERENCE TO CONTAINER SEGREGATION Ref: (a) 49 Code of Federal Regulations Parts 100 to 185 1. As per 49 CFR 105.20, 1 am requesting guidance for the following situation: fore and aft or not less than 2.5m athwartship. a. 49 CFR 176.83(f)(4) states that a container space means a distance of not less than 6m b. 49 CFR 176 does not define "fore and afi" or "athwartships". ENCLOSURE 1 for a diagram, does the "fore and aft" container space (6m), or the c. In instances when a container is looated one bay and two rows away from another, see "athwartships" container space (2.5m) apply in regards to segregation of 2, "Separated from"? 2. Any guidance or definition would be appreciated. # of 2, closed versus closed situation Enclosures: (1) IMDG Code (AMDT. 30-00) page337, Diagram of vessel showing segregatir2#

Page 308/28/2085 89:38 757-856-2494 MARINE SAFETY BRANCH PAGE 03/03 ...am. Chapter 7.2 - Segregation "AWAY FROM" .1 OPEN VERSUS OPEN HORIZONTAL ON DECK UNDER DECK VERTICAL FORE AND AFT One container space On continer sace or unless segregated by a deck NOT In the same vertical line ATHWARTSHIPS One container space One container space - AR Longitudinally Fwd. Port Athwartships SIb. Deck CINN NN LN Hold N MINK Top view deck Top view hold TPort Note: All bulkheads and decks should be resistant to fire and liquids. 1 - Situation open versus open "SEPARATED FROM" .2 CLOSED VERSUS CLOSED ON DECK HORIZONTAL UNDER DECK VERTICAL FORE AND AFT One container space One container space or one bulkhead NOT In the same vertical line ATHWARTSHIPS One container space unless segregated by a deck Aft Longitudinally Furd. Deck Hold Top view deck I Port situation- I SIb Note: All bulkheads and decks should be resistant to fire and liq FNCLOSURIE (1) 2 - Situation closed versus closed#