{"operation":"document","citation":"11-0173","title":"Department of the Army- SDDC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-09-01","effective_on":null,"summary":"11-0173 response to Department of the Army- SDDC concerning 176.144, 176.170, 176.83.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0173.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0173.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0173","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110173.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Avenue, SE\nWashington, DC 20590\nPipeline and Hazardous Materials\nSafety Administration\nSEP 0 1 2011\nMr. Daniel A. Maham\nDirector of Safety\nDepartment of the Army- SDDC\n1 Solider Way, Bldg 1900W\nScott AFB, IL 62225\nReference No.: 11-0173\nDear Mr. Maham:\nThis responds to your July 25, 2011 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the on deck\nsegregation of freight containers carrying incompatible explosives in accordance with\n§ 176.144(a). In particular, you ask if these freight containers must be segregated 20 ft\n(6m) fore and aft and 8 feet (25m) athwartship from each other in accordance with\n§ 176.170(f) or 20 feet (6m) from each other in all directions in accordance with\n§ 176.144(e).\nFreight containers carrying incompatibJe explosives must be segregated in accordance with\n§ 176.170(f) and 176.83(f) or 176.83(1)(3), as appropriate. Section 176.144(e) does not\napply to the segregation of incompatible explosives in separate freight containers.\nAlthough not specifically stated, § 176.144(e) only applies to the segregation of individual\npackages, pallets, or magazines containing incompatible explosives when on deck.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nDelmer Bi~./#-\nSenior Regulations Advisor, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDEPARTMENT OF THE ARMY\nMILITARY SURFACE DEPLOYMENT AND DISTRIBUTION COMMAND\n1 SOLDIER WAY, BLDG 1900W\nSCOTT AFB, IL 62225·5006\nREPLY TO\nATIENTIONOF\nJuly 25,2011\nDirectorate of Safety (AMSSD-SA)·\nOffice of Hazardous Materials Standards, Pipeline and Hazardous Materials Safety Administration\nATTN: PHH-IO\nUS Department ofTransportation, East Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nDear Madam/Sir:\nIn accordance with the' provisions ofTitle 49, Code ofFederal Regulations (CFR), Part 105, Section\n105.20, the Department of Defense (DOD) hereby requests an Interpretation of the Hazardous Materials Regulations\nas outlined below. DOD petitions for a clarification of contrasting information from standard numbers 49 CFR\n176.144 and 49 CFR 176.170. The following file number is assigned:\nFile Number: 54-11 (0721)\nRe: Request Interpretation of 49 CFR 176.144, Segregation of Class I (explosive) materials and 49 CFR\n176.170, Transport of Class I (explosive) materials.\nProponent: Department ofDefense (DoD)\nThis question pertains to the regulations concerning segregation ofHazardous Material Class 1 stored on\ncontainer ships. Standard number 49 CFR 176.144(e) states that, \"When Class 1 (explosive) materials of different\ncompatibility groups are carried on deck, they must be stored not less than 6 m (20 ft) apart unless they are allowed\nunder Table 176. 144(a) to be stowed in the same compartment, magazine, or cargo transport unit.\"\nOn the other hand, standard number 49 CFR 176.170(1), which specifically addresses Class 1 shipment in\nfreight container units, requires that such freight containers be separated from each other in accordance with Table\n176.83(1), which in this case requires one container space fore, aft, and athwartships. The container space is then\ndefmed in standard number 49 CFR 176.83(1)(4) as 6m (20 ft) fore and aft, and 2.5 m (8ft) athwartships.\nWhile both standards refer to the storage ofClass 1 materials that are incompatible in accordance with\nTable 176.144(a), the standard that directly covers freight container storage of Class I material designates specific\ndistances in three directions, rather than the general distance for Class I in all types of Class 1 storage. Does then,\nincompatible Class 1 material as defmed by Table 176.144(a), stored in freight containers, follow the separation\nrequirements of standard number 49 CFR 176.170 (6 m (20 ft) fore and aft, and 2.5 m (8 ft) athwartships) or\nstandard number 49 CFR 176.144 (6 m (20 ft) in an directions)?\nThe point ofcontact for this organization is Mr. Tom Briggs. He can be reached via mail, at (618) 2205039,\nor at Thomas.h.briggs@us.army.mil. Thankyou for your time in this matter and we look forward to your\nrapid response.\nSincerely,\n~. ;/Je .#!~,\nDanie~~m\nDirector of Safety\n____\nPrinted on • Recycled Paper","truncated":false,"body_characters":4312}