{"operation":"document","citation":"07-0172","title":"Allegro MicroSystems, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-10-29","effective_on":null,"summary":"07-0172 response to Allegro MicroSystems, Inc concerning 171.8, 173.6.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0172.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0172.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0172","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070172.pdf","body":"<<<PAGE 1>>>\n\nf Transportatio\n.S. Departmer\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safety\nipeline and Hazardou\nAdministration\nOCT 29 2007\nMr. Donald W. Alger\nRef. No.: 07-0172\n115 Northeast Cutoff, Box 15036\nAllegro MicroSystems, Inc.\nWorcester, MA 01615\nDear Mr. Alger:\nexception prescribed in § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts\nThis responds to your letter dated August 30, regarding clarification of the materials of trade\n171-180), as it applies to the transport of \"UN1219, Isopropyl alcohol, 3, PG II\" between\nseveral of your company's chemical plants.\nYou state that your company is located in Worcester, Massachusetts and a \"sister\" plant is\nlocated in Manchester, New Hampshire. From time to time, you get a request from the\nManchester plant for some Isopropyl alcohol. You ask whether the materials of trade\n(MOTs) exception in § 173.6 applies to the transport of the Isopropyl alcohol (or other\nchemicals) in your company-owned and-operated vehicles from your Worcester plant to your\nManchester plant.\nA material of trade is defined in § 171.8, as a hazardous material, other than a hazardous\nwaste, that is carried on a motor vehicle:\n(1) For the purpose of protecting the health and safety of the motor vehicle operator or\npassengers;\n(2) For the purpose of supporting the operation or maintenance of a motor vehicle\n(including its auxiliary equipment); or\n(3) By a private motor carrier (including vehicles operated by a rail carrier) in direct\nsupport of a principal business that is other than transportation by motor vehicle.\nBased on your scenario, it appears that your company meets the third criteria. Provided that\nIll conditions in § 173.6 are met, your company may take advantage of the MOTs exceptior\nTazardous materials that are transported in accordance with $ 173.6 are not subiect to an\nIn accordance with § 173.6, the Isopropyl alcohol you transport between your facilities must\nbe in a packaging with a gross mass or capacity no greater than 66 pounds or 8 gallons. You\n173.6\n070172\n171.8\n\n<<<PAGE 2>>>\n\nmay transport more than one package in the same vehicle provided that the aggregate gross\nweight of the MOTs on the vehicle does not exceed 440 pounds. Packages must be leak tight\nmovement, and protected against damage. Each material must be packaged in the\nfor liquids and gases, sift-proof for solids, and be securely closed, secured against shifting or\nmanufacturer's original packaging, or a packaging of equal or greater strength and integrity.\nI hope this satisfies your inquiry.\nIf we can be of further assistance, please contact us\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nRequest for Determination\ningrum\nPage 1 of 1\n3172. 700\nDrakeford, Carolyn <PHMSA>\n$ 173.6\nFrom: INFOCNTR <PHMSA>\nTraining\nSent: Thursday, August 30, 2007 11:14 AM\nTo:\nDrakeford, Carolyn < PHMSA>\n07-0173\nSubject: FW: Request for Determination\nWants a written letter of Interp.\nFrom: Alger, Donald W [mailto:DAlger@ALLEGROMICRO.com]\nTo: INFOCNTR <PHMSA>\nSent: Thursday, August 30, 2007 10:11 AM\nCc: Mahoney, Denis C; Moquin, William T\nSubject: Request for Determination\nCompleted via phone by RB @ 11:10 am on 8/30\nHello,\nI am contacting you for a Request for Determination. We are located in Worcester, MA and have a sister plant in\nfew. From time to time we get a request from them for some isopropyl alcohol (IPA). My question is whether\nManchester, NH. We use a reasonable amount of chemicals in our process, but the Manchester plant uses very\ntransport of this IPA (or other chemicals) from here to Manchester falls under the Materials of Trade rule. Can our\nrequirements for these employees? Regarding quantity limits, do we follow those specified in the \"What Are\nemployees legally transport IPA or other chemicals to the Manchester plant, or vice versa? Are there any special\nMaterials of Trade\" booklet?. For IPA, it specifies a limit of 8 gallons in each package. Does that mean you can\ntransport 16 gallons as long as there are no ore that 8 in each package?\nThank you.\nDonald W. Alger\nSenior Environmental Engineer\nAllegro MicroSystems, Inc.\n115 Northeast Cutoff, Box 15036\nWorcester, MA 01615\nfax (508) 856-7435\nphone (508) 854-5560\ndalger@allegromicro.com\n8/31/2007","truncated":false,"body_characters":4298}