Commonwealth of Virginia Department of State Police — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 20590 400 Seventh Street, S.W FEB 8 2007 Sgt. David P. Feather Ref. No.: 07-0003 partment of State Poli mmonwealth of Virgin 9801 Braddock Road Fairfax, VA 22032 Dear Sergeant Feather: Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the transportation of gasoline This is in response to your December 29, 2006 letter requesting clarification of the Hazardous in intermediate bulk containers (IBCs). Specifically, you ask whether there is an oversight in Column 7 of the § 172.101 Hazardous Materials Table regarding the use of Special IBC Packing Provision IB2 for a material classed as "Gasoline, 3, UN1203." pressure less than or equal to 110 kPa at 50°C (1.1 bar at 122 F), or 130 kPa at 55 C (1.3 bar at The answer is no. Special IBC Packing Provision IB2 is only authorized for liquids with a vapor Provision IB2 is not authorized for a material classed as "Gasoline, 3, UN1203." 131 F). The vapor pressure of gasoline exceeds these amounts; therefore, Special IBC Packing this office. I hope this information is helpful. If you have further questions, please do not hesitate to contact Sincerely, Charles E. Betts Senior Transportation Specialist Office of Hazardous Materials Standards 172 /01 070003#

Page 2BAH §172.101 $173.242 Bulk Packagings COMMONWEALTH OF VIRGINIA DEPARTMENT OF STATE POLICP December 29, 2006 Mr. Edward T. Mazzullo U.S. DOT/PHMSA (PHH-10) Director, Office of Hazardous Materials Standards 400 7th Street S.W. Washington, D.C. 20590-0001 Dear Mr. Mazzullo: I respectfully request a clarification concerning the transportation of Gasoline in Intermediate Bulk Containers. In the current edition of 49 CFR, the table entry for Gasoline, there are no special provisions that allow for the use of an IBC. The bulk package section in column 8C of the § 172.101 table directs you to § 173.242. As stated in 173.242(d), an IBC is authorized, subject to conditions and limitations in this section, provided the IBC type is authorized according to the IBC packing code specified for the specific malerial in column / of the § 172.101 Table. In referring to column 7, the only Special Provisions are 144, B1, B33, and T8, none of which would authorize an Intermediate Bulk Container. In earlier editions of 49 CFR authorized the use of IBC's to transport gasoline through been removed and special provision B1 inserted. In looking through the table there are special provision IB2. In the 2003 edition of 49 CFR until now, this special provision has numerous other Class 3 materials in Packing Group Il that are authorized to be transported in IBC's. I question if this is an oversight in the table. Any help in this matter would be greatly appreciated Sincerely, Balf Zeach David P. Feather, Sergeant#