Guidanceguidance
06-0033
Mr. Christian W. Solum — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research06-0033
Page 1S. Departme Transportatio 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazarcious Materials Safety MAR 2009 Mr. Christian W. Solum Ref. No. 06-0033 Building 704-3N, Rm S111D Aiken, SC 29808 Dear Mr. Solum: This is in response to your February 6, 2006 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a limited quantity Class 7 (Radioactive) material could also meet the definition of a Class 9 (Miscellaneous) material in accordance with the HMR. The answer is no. For the purposes of the HMR, a Class 9 material is defined as "a material which presents a hazard during transportation but which does not meet the definition of any other hazard class." See § 173.140. The material in question does not meet the definition of a Class 9 material because it meets the definition of another hazard class. I hope this information is helpful. Sincerely, Loma tro (Chief, Standards Development Office of Hazardous Materials Standards 173.140 060033#
Page 2SRS SAVANNAH RIVER SITE Aiken, SC: 29808 • www.srs.gov Eichenlaud February 6, 2006 $173.140 Office of Hazardous Materials Standards Definition Pipeline and Hazardous Materials Safety Administration Attn: PHH-10, 06-0033 U.S. Department Of Transportation Washington Sc DC 20590-0001 LIMITED QUANTITY CLASS 7 INTERPRETATION REQUEST It is the position of Washington Savannah River Company (WSRC) that Class 9 materials described in 173.140 shall not meet the definition of any other hazard class and must not be represented as having a subsidiary hazard of any other hazard class. Specifically in question is a material meeting the definition of a limited quantity Class 7. If a material meets the definition of a limited quantity Class 7 material, it cannot meet the definition of a Class 9 material. WSRC hereby respectfully request a formal interpretation regarding its position. Respectfully, Christian Vi. Solum: Christian W. Solum, Hazardous Material Shipping Advisor Washington Savannah River Company Building 704-3N, Rm S111D Aiken, SC 29808 1-803-557-4689 Christian.solum@srs.gov WASHINGTON SAVANNAH RIVER COMPANY Corporation By Swaman Suer Company a CHL Servana River Company River. C. • NG Amarica Sawana fiver#
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