United States Coast Guard — Hazardous Materials Safety Interpretation

Page 1MAR 9 2007 Wash ngton, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration Mr. J.E. Pomajzl Second Class Marine Science Technician (MST2) Ref. No.: 07-0010 2760 Sherwood Lane Suite 2A United States Coast Guard Juneau, AK 99801 Dear Mr. Pomajzl: This is in response to your January 10, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to vessel stowage requirements. Your questions are paraphrased and answered below: Certain deck barges stow containers perpendicular to the center line (container entrance facing either port or starboard on deck) versus parallel to the centerline as found on most does the term "container space" still need to meet the definition found in § 176.83(f)(4) container ships. For deck barges that stow containers perpendicular to the centerline, which defines a "container space" as distance of not less than 6 m (20 feet, fore and aft or not less than 2.5 m (8 feet) athwartship. Al. The answer is yes. Although the definition of "container space" in § 176.83(f)(4) is based on the dimensions of a typical 20 foot container when in parallel with the keel, the definition is a distance, 6 m (20 feet) fore and aft or not less than 2.5 m (8 eet) athwartship. Q2. Can the definition of "container space" change to 2.5 m (8 feet) fore and aft when the containers are stowed on deck perpendicular to the centerline? A2. The answer is no, the definition does not change when containers are stowed on deck procedures at the discretion of the Captain of the Port (COTP), who must determine if the perpendicular to the centerline. However, § 176.65 does allow for alternat ve stowage alternative stowage procedures will insure a level of safety at least equal to that afforded by regulatory requirement concerned. Q3. What method is used by the COTP to "insure a level of safety at least equal to that afforded by regulatory requirement concerned?" 176.83 176.65 070010#

Page 2The COTP has the discretion to use any method when allowing an alternative stowage to prevent a fire from spreading to other containers, if such an event occurs. procedure. For example, the COTP may require fire resistant barriers between containers this office. I hope this information is helpful. If you have further questions, please do not hesitate to contact Sincerely Matth Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention#

Page 3Homeland Security U.S. Department of Crmmander United States Coast Guard 2760 Sherwoor Lane. Ste 2A United States Sector juneau Juneau. AK 99801 Fax: 907 463-2455 907-46: 2445 Coast Guard 16703 Satterthunute 10 lan 200? $116.83 MEMORANDUM $ 176.65 vessel From: 1E. PONNAL MST2 ESCO Reply to 07-0010 Altn of: USCG 1. E. POMAJZI.. MST2. To: PHMSA - OFACE OF HAZARDOUS MATERIALS STANDARDS Subj: GUIDANCE REGARDING THE APPLIATION OF STOWAGE AND STOWAGE SEGREGATION REGULATIONS TO DECK BARGES WITH NON-STANDARD Ref (a) Title 49 Code of Federal Regulations (CFR). Parts 100-185 1. As per Title 49 CFR. Part 105.20. 1 am seeking guidance on the following situation: (container entrance facing cither port or starboard on deck) versus parallel to the centerline as a. Certain deck barges in Southeast Alaska stow containers perpendicular to the centerline found on most container ships (container entrance facing bow or stern). container space" still need to meet the definition found in Title 49 CFR. Part 176.83(D(+) which b. For deck barges that stow containers perpendicular to the conterline. does the term than 2.5m (8 feet) athwartship? Can the definition of container space change to 2.5m (8 feet) states a container space means a distance of not less than 6m (20 feet) fore and aft or not less fore and aft when the containers are stowed on deck perpendicular to the centerlin:? Part 176.65? Iask this bec rose if the definition of a container space is fixed at on (20 fee:) than c. What method is used to determine an 'equivalent level of safety" as found in Title 40 CFR. shippers in Southeast Alaska may run into compliance difficulties and need to develop different solutions to stowage problems on barges that carry containers perpendicular to the conterline. problem based on a real incident Coast Guard inspectors found. If you require fur her ZAny guidance on this would be appreciatedT have enclosed an dxample of the slowage clarification of the problem, please call me at (907) 463-2454. Thank you. ##

Page 4Boul Red / Dark Color represent hazardous containers Example of Acceptable PORT compartment or hold from" stowage. 1 container space "Separated From" & "Separate by a complete separation required and not in the same vertical stack. STARBOARD 32' 4 compartment or hold from" This requires four container "Separated longitudinally by an intervening complete spaces of separation. Must be stowed on deck. DOT: 011505 c is ajace lanes reguis are spanion segretainers with Tegula sons are mastied every year by the urinat gorariment a the actual 49 FR requirements supersedes anything printed in this diagram STERN -#

Page 5Chapter 6 Barge Segregation of Hazardous Materials hazardous material per section 176.83. The table below shows the segregation requirements for placarded We are required to provide segregation or separation between containers when they contain some classes of sticker (DOT-E 11503) adjacent to the placard it is exempt from segregation requirements. If there is not an hazardous containers when stowed on a barge. Note that if a container has a placard and a DOT exemption exemption sticker it must be segregated as required below. Note that two containers of the same hazard class are considered compatible and can be stowed together with no segregation between them. (Segregation must also take account of a single sacondary hazard label, as required by paragraph (a)(6) of this rection.) TABLE 178.83(b)—GENERAL SEGREGATION REQUIREMENTS FOR HAZARDOUS MATERIALS Class $.3 1: 4.3 5.1 5.2 8 9 Explosives, 1.1, 1.2,1.5......... Explosives, 1.4, 1.6......... Explosivos, 1.3...... Flammable gases 2.1......................... Non-foxic, non-flammeble gases 2.2....... * XXX*NN *****××. Flammable liquids 3.. Polsonous gases 2................... Spontaneousty combustible substances 4.2.... Flammable solds 4.1 ............ Substances which are dangerous when wet 4.3. XNNANDAAQOANNA 333 X-NAXNNXN-NXXXNAA X-NG-NN-X -NN-NNWA X-NNXNNX-X*XXXNAA OX-CONCOONNARAD Organic peroxides 5.2...... Oxidtzing substances 5.1 ....... Polsona.1..... Radioactive materials 7.... Infectious substances 6.2. Miscellaneous dangerous substances 9 Corrosives 8. XANA NA XXNOX~N. xx- closed. Below is the description of segregation required for each case. The stowage restrictions For "On Deck" Barge Stowage Segregation refer to Table 176.83(f). Columns for closed versus below are based on our interpretation of 49CFR. These regulation are modified every year by the Federal Government so the current 49 CFR supersedes anything printed in this section. 1 & X = Requires no segregation. not permitted. 2 & 3 = Separated by one container space horizontally and stowage in the same vertical stack is 4 = Requires 4 container spaces separation horizontally and must be stowed on deck. (*') = Maintain 20' of separation unless compatibility groups are compatible as determined in Table 176.144(a). containing hazardous materials that we handle most often. Below is a quick reference of segregation requirements for some of the containers Non-flammable gas 2.2 Haz-Mat Corrosive Haz-Mat 8 None Segregation Required Non-flammable gas 2.2 Flammable gas 5.1 None Flammable gas 2.1 2.1 corrosive )xidizer 8 None Flammable gas 2.1 Non-flammable gas 2.2 5.1 None One container space Oxidizer 5.1 "Corrosive One container space deck only. Note: All Explosives Containers regardless of their classification must be stowed in first ier on#