Guidanceguidance
07-0053
Allied Universal Corporation — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research07-0053
Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration APR 4 2007 Regulatory Affairs Manager Mr. Robin J. Eddy Bolte Ref. No.: 07-0053 Allied Universal Corporation 3901 NW 115 Avenue Miami, FL 33178 Dear Mr. Bolte: This responds to your letter dated March 1, 2007, regarding whether a material described as "Sulfur dioxide, 2.3, UN1079" is regulated under the Hazardous Materials Regulations (HMR 49 CFR Parts 171-180) as a hazardous substance requiring entry of the letters "RQ" on shipping papers and package markings. The answer is no. Under the HMR, "Sulfur dioxide" is not specifically listed as a definition of a hazardous substance in $ 171.8. The letters "RQ" may not be shown on hazardous substance in § 172.101, Appendix A and, therefore, does not meet the the shipping paper or package marking in association with the proper shipping name. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, / Office of Hazardous Materials Standards 172.101 171.8 070053#
Page 2Engrum 3172.101 3172.202 3901 NW 115 Avenue $172.203 Miami, Florida 33178 305-888-2623 office Shipping Papers 305-885-4671 fax ALLED UNIVERSAL CORPORATION Established 1954 07-0053 March 1, 2007 Director of Hazardous Materials Standards Development Mr. Edward Mazzullo Office of Hazardous Materials Standards Development 400 Seventh Street, S.W. Pipeline and Hazardous Material Safety Administration Washington, D.C. 20590-0001 VIA FASCIMILE: 202-366-3012 Re: Reportable Quantity Shipping Paper & Marking Requirements (49 CFR 172 Subpart C and D) Dear Mr. Mazzullo: We transportship one-hundred and fifty-pound DOT specification cylinders and one ton DOT specification multi-unit tank car tanks, From Statelaw enfergement regarding containers of sulfur dioxide, specifically relating to the hazardous substance requirements commonly refertgo-lo as a ton container, of sulfur dioxide. However, we are receiving conflicting citations and regulatory advice found in 49 CFF 1R9 • Subpart C and D Backarou is not listed in 49 CFR 172.101 Appendix A, Hazardous Substance Table. Sulfur Dioxide is not listed in us Substances and Their Threshold Planning and Reportable Quantities Table. In the table found at 40 pe and Reportable Quantities Table in 40 CFR 302.4. Sulfur Dioxide is listed in 40 CFR 355 Appendix FB355 AD Sportable quantity for Sulfur Dioxide is 500 pounds. doxide equal to eulater than 500 pounds require the letters RQ (reportable quantity to be entered on the shipping paper and Gestion: Tog de confficing cifations and regulatory advice received over the years, does a container or package or sulfur package (as sail Stated in 49 CFR Subpart G and Subpart D)? Your promptness in responding to our question is greatly appreciated. Your hazardous material information hotline has been helpful, but given the conflict belween various State law enforcement, a written interpretation is needed RobinE@Allieduniversal.com. If you should have any questions or further information Is needed, please call me at 305-888-2623, extension 183 or Thank you. Thin fate Robin J. Eddy Bolte Allied Universal Corporation Regulatory Affairs Manager 305-885-4671 (Fax) 305-888-2623, ext. 183 RobinE@Allieduniversal.com 2°d 6662-908-616 эпи LET 002 I JEW#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.