# Sea Star Line LLC — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 07-0155
- **title:** Sea Star Line LLC — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2007-10-16
- **effective on:** Not available
- **summary:** 07-0155 response to Sea Star Line LLC concerning 171.8, 176.305.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-07-0155.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-07-0155.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-07-0155
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070155.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S. Department
1200 New Jersey Avenue, SE
Washington, D.C. 20590
Pipeline and Hazardous
Administration
Materials Safety
ПСТ 16 2007
Mr. Shawn Burke
Sea Star Line LLC
Manager, Terminal Operations
Ref. No. 07-0155
Elizabeth, New Jersey 07207
Dear Mr. Burke:
This responds to your August 9, 2007 fax requesting clarification on the definition of
ventilation related terms under the Hazardous Materials Regulations (HMR; 49 CFR Parts
"mechanically ventilated" holds in vessels under the HMR.
171-180). Specifically, you ask for the definitions of "ventilated", "well ventilated", and
Generally, there are two types of ventilation for a cargo hold: mechanical ventilation and
natural ventilation. Mechanical ventilation can be simply defined as power-generated
ventilation. For Safety of Life at Sea (SOLAS) vessels, this typically means at least six air
vapors from the upper or lower parts of the cargo space. This definition can be found in
changes per hour in the cargo space, based on an empty cargo space, and the removal of
SOLAS Chapter II-2 Regulation 19. Natural ventilation is simply ventilation that is not
power-generated. This type of ventilation usually takes the form of openings, vents, or
Under the HMR, "ventilated" means the removal of dangerous vapors and gas from the cargo
hold. Either natural or mechanical ventilation may be used provided the ventilation system
has the capacity to prevent a dangerous accumulation of vapors or gases. For purposes of the
Part 176 of the HMR, "well ventilated" has the same meaning as "ventilated."
I hope this answers your inquiry.
Sincerely,
2A89X
Chief, Standards Development
Office of Hazardous Materials Standards
171.8
176.305(011)
070155

<<<PAGE 2>>>

Drakeford, Carolyn <PHMSA>
From:
Sent:
INFOCNTR <PHMSA>
Subject:
To:
Drakeford, Carolyn <PHMSA>
Thursday, August 09, 20074:44 PM
Boothe
FW: Interpretation
3|71. 8
Bennissep
Wants a written letter of Interp.
-----Original Message-----
07-0155
From: shawnburke@seastarline.com [mailto: shawnburke@seastarline.com]
To: INFOCNTR <PHMSA>
Sent: Thursday, August 09, 2007 4:30 PM
Subject: Interpretation
To who it may concern:
I am interested in an interpretation / definition of the terms
"ey alated 49, taras 00 to 185 as tay a ve cach listed ad
and "mechanically ventilated" holds as
distinct stowage provisions in the CFR.
I was unable to find definitions in the CFR
or on the PHMSA website.
reply
Many thanks for your assistance this matter
I look
forward
to your
Respectfully Submitted
Mr. Shawn Burke
Manager - Terminal Operations
Sea Star - Elizabeth / Houston
(908) 965-0601

<<<PAGE 3>>>

•
Boothe, Deborah <PHMSA>
Sent:
From:
Boothe, Deborah <PHMSA>
'Richard.C.Bornhorst@uscg.mil'
Tuesday, October 09, 2007 9:10 AM
Subject:
RE: 07-0155
Boothe, Deborah <PHMSA>
Importance:
High
Richard,
Thank you! Have a great day!
Deborah Boothe
Transportation Regulations Specialist
202-366-4478
PHMSA/Office of Hazardous Materials Standards PHH-10
From: Richard.C.Bornhorst@uscg.mil [mailto:Richard.C.Bornhorst@uscg.mill
-----Original Message-----
Sent: Tuesday, October 09, 2007 8:49 AM
Subject: RE: 07-0155
To: Boothe, Deborah <PHMSA>
Deborah,
need anything else.
The interpretation looks good.
I'm sorry I haven't responded sooner. Let me know if you
Chemical Engineer
Richard C. Bornhorst
Hazardous Materials Standards
(202) 372-1426
U.S. Coast Guard
From: deborah.boothe@dot.gov[mailto:deborah.boothe@dot.gov]
•----Original Message-----
To: Bornhorst, Richard
Sent: Friday, October 05, 2007 3:17 PM
Subject: FW: 07-0155
Cc: deborah.boothe@dot.gov
Importance: High
Good afternoon Richard,
'm just following up to see how your review/concurrence is progressing on clarificatio
etter Ref. No. 07-0155 on ventilation. Thank you again for your review/concurrence
Have
great
weekend.
Deborah
From: Boothe, Deborah <PHMSA>
To: Bornhorst, R
Sent: Tuesday, September
sopranbor 13, 2007 2:55 pm
Subject: 07-0155
Cc: Boothe, Deborah <PHMSA>
Importance: High
1

<<<PAGE 4>>>

•
Good afternoon Richard,
Attached is the letter on ventilation with your revisions/edits incorporated. Please
Chank you again for your assistance. Hope you're having a great day.
review/concur for grid purposes if you concur with this version of the letter/response.
Deborah Boothe
DOT / PHMSA
Office of Hazardous Materials Standards/PHH-10
2

<<<PAGE 5>>>

USCO Input 60r 07-0155
Boothe, Deborah <PHMSA>
From:
[Richard.C.Bornhorst@uscg.mil]
Richard.C.Bornhorst@uscg.mil on behalf of Bornhorst, Richard
Sent:
To:
Wednesday, August 22, 2007 9:51 AM
Subject:
RE: Request for assistance on interp letter Ref. No. 07-0155: Definitions of "ventilated", "well
Boothe, Deborah <PHMSA>
ventilated" and "mechanically ventilated"
Deborah,
I received the fax.
will try to answer...
slightly different meanings given the context
or lower parts of the cargo space.
the cargo space, based on an empty cargo space,
Regulation 19.
ventilation usually takes the form
Natural ventilation is simply ventilation that is not power-generated.
of openings, vents, or goosenecks in the cargo hold.
This type of
gas from the cargo hold.
In the context of the HMR, I take "ventilated" to mean the removal of dangerous vapors and
the ventilation system has the capacity to prevent a dangerous accumulation of vapors or
Either natural or mechanically ventilation may be used provided
this term is only used in a three locations in Part 176: 176.93 (d), 176.84 (b) Code 84, and
I take "well ventilated" to mean the same thing as "ventilated." To my knowledge
176.400 (b). I did a search for Code 84 and it is not assigned to single entry in the
reference in 176.400 (b) refers to the stowage of organic peroxides. I think the use of
Hazardous Materials Table. The reference in 176.93 (d) could simply be "ventilated." The
additional requirements.
"well" here is simply to stress the importance of ventilation rather than impose
mechanically ventilated under SOLAS.
Furthermore, organic peroxides are not required to be
likely how it found its way into the HMR.
It should also be noted that the vague
terminology also appears in the IMDG Code and is
in the Code but there has not been wide support for prescriptive ventilation requirements.
Attempts have been made to provide definitions
interpretation with the idea that the definition may vary depending on the context of the
Since this interpretation request is fairly general/vague in nature I would caveat the
reference in the HMR and the hazardous materials to be carried.
Let me know if you need anything else.
Best Regards,
Richard C. Bornhorst
Chemical Engineer
U.S. Coast Guard
lazardous Materials Standards
(202)
372-1426
From: deborah.boothe@dot.gov[mailto:deborah.boothe@dot.gov]
-----Original Message--
2007
1:33 PM
"ventilated",
"well ventilated"
assistance on interp letter Ref. No. 07-0155: Definitions of
Importance: High
"mechanically ventilated"

<<<PAGE 6>>>

"Thanks Richard. I just faxed the incoming request for interpretation to you a couple of
Deborah
minutes ago. Have a great weekend.
-----Original Message-----
From: Richard.C.Bornhorst@uscg.mil [mailto:Richard.C.Bornhorst@uscg.mil]
To: Boothe, Deborah <PHMSA›
Sent: Friday, August 17, 2007 11:23 AM
Definitions of "ventilated",
subject: RE: Request for assistance on interp letter Ref. No. 07-0155:
"well ventilated" and "mechanically ventilated'
My fax #: 202-372-1926
Chemical Engineer
Richard C. Bornhorst
Hazardous Materials Standards
U.S. Coast Guard
(202) 372-1426
--Original Message---.--
rot: Friday, August 17, 2007 11:18 Adeboran. boothe@dot.gov
To: Bornhorst, Richard
2007 11:18 A
Sebjections Requent at stand entinated enter Rehanically ventilated"
Definitions of
Importance: High
"ventilated", "well ventilated"
If you would rather we
fax number, I'll fax
to my supervisor,
DOT/PHMSA/Office of HazMat Stds/PHH-10
Deborah Boothe
202-366-4478
From: Richard.C.Bornhorst@uscg.mil [mailto:Richard.C.Bornhorst@uscg.mil]
-----Original Message-----
Sent: Friday, August 17,
2007 11:03 AM
Definitions of "ventilated"
Deborah,
Team hate to hop old and not feast fad dized ye company oaki pass how to
I am happy to help out any way I can.
interpretation request and I will get back
to you with some guidance.
Richard C. Bornhorst
Hazardous Materials Standards
Chemical Engineer
(202) 372-1426
U.S. Coast Guard
-----Original Message-----
To: Bornhorst, Richard
Sent: Friday, August 17, 2007 10:49 AM
Cc: deborah. boothe@DOT.GOV
Definitions of "ventilated", "well ventilated" and
Subject: Request for assistance on interp letter Ref. No.
"mechanically
07-0155:
2

<<<PAGE 7>>>

-Importance: High
Good morning,
definitions of: "ventilated", "well ventilated", and "mechanically ventilated", holds
I've been assigned to draft a response to a request for an interp that asks for the
regarding vessel stowage under the HMR.
in the HMR and I have not found any specific definitions for these terms.
Houston, Texas.
definitions for these terms or can you give me some language to use to define each of
Do you have any
approximately two weeks to complete my first draft response. So, any information you can
I'd appreciate any assistance in completing my first draft response.
give me before the end of August would be greatly appreciated!
Thank you very much for your assistance. Have a great day and weekend.
Deborah Boothe
DOT/PHMSA/Office of HazMat Standards/PHH-10
1200 New Jersey Ave, SE
Washington, DC
20590
202-366-4478
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