{"operation":"document","citation":"16-0112","title":"Atlantic Ro-Ro Carriers, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-11-30","effective_on":null,"summary":"16-0112 response to Atlantic Ro-Ro Carriers, Inc. concerning 171.25, 173.403, 176.704, 176.708.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0112.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0112.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0112","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/160112.pdf","body":"<<<PAGE 1>>>\n\nMr. Andrei Lazourenko\n1S VP\nAtlantic Ro-Ro Carriers, Inc.\n95 River Street, 3rd Floor\nHoboken, NJ 07030\nRef. No. 16-0112\nDear Mr. Lazourenko:\nThis responds to your June 23, 2016 email requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171-180) applicable to § 176.708. Section 176.708 requires\na minimum separation distance between radioactive materials and those spaces regularly\noccupied by crewmembers and passengers or undeveloped photographic film. As indicated in\nparagraph (a) Table IV identifies the minimum separation distance as a function of the sum of\nthe transport indexes (TIs) of all packages in a single consignment.\nYou provide an example of a vessel transporting Class 7 (radioactive) material in 100 20-ft.\ncontainers, each having a TI of 2, and placed in different cargo compartments. You ask for\nclarification on the definition of \"consignment\" when calculating the minimum separation\ndistance. You also ask if stowage on the weather deck is considered a single consignment.\nAlthough not detailed in Part 176, consignment as specifically defined in § 173.403 of the\nHMR, means a package or group of packages or load of radioactive material offered by a\nperson for transport in the same shipment. When calculating the minimum separation distance\nusing Table IV in § 176.708, the sum of TIs of the packages should be calculated assuming the\nconsignment is for all the packages transported aboard the vessel. This calculation is\nregardless of whether the containers are stowed on different decks or separate compartments.\nFor your example, and for the purposes of Table IV in § 176.708, the sum of the TIs of the\npackages is 200.\nPlease note that § 176.708(d)(2) provides a secondary method for calculating the minimum\nseparation distances between radioactive materials and crew member and passengers for\nconsignments on board a vessel under the exclusive use conditions of § 176.704(f).\n\n<<<PAGE 2>>>\n\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nPlease submit this as a letter of interpretation. Mr. Lazourenko spoke with Eamonn in the Info Center.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: ARRC Andrei Lazourenko [mailto:andrei@arrcm.com]\nSent: Thursday, June 23, 2016 3:46 PM\nTo: INFOCNTR (PHMSA)\nSubject: Request for interpretation\nUS DOT\nPipeline and Hazardous Materials Safety Administration\nHereby, we would like to receive written interpretation of the definition of \"consignment\" as provided in para 176.708\n(a) of CFR 49 to consider the separation distance as sum of Tl's in a single consignment.\nAs an example, a vessel has on board 100x20' containers with cl.7 where each container has TI = 2 and the containers\nare stowed in different cargo compartments (hold nb.1, tweendeck nb.1, hold nb.2, twd. Nb. 2, etc and weather deck).\nWith such stowage, would a \"consignment\" be defined as the whole number of cl.7 cargo on board or per each\ncompartment and designated deck area in order to consider min distance from living quarters as shown in table IV of\npara 176.708 of CFR 49?\nAlso, please clarify if the stowage onto weather deck area to be considered as single consignment or not in terms of\ndefining the safe distance between cl.7 cargo and the living quarters on a vessel. - May be multiple\n\"de fired deckari\nIf you have any questions you can contact me at any time.\n178.704\nIf your reply to be mailed, please use address as shown in my signature below.\nThanks in advance,\nRegards,\nAndrei Lazourenko\n15 VP\nATLANTIC RO-RO CARRIERS, INC.\n95 River Street | 3d Floor | Hoboken | New Jersey | 07030 | U.S.A.\n(O) +1.201.356.2300 | (D) +1.201.356.2305| Skype: lazar 1974\n(C) +1.201.406.6455 | (F) +1.201.356.2299 | E-mail: andrei@arrcm.com\n1\n\n<<<PAGE 4>>>","truncated":false,"body_characters":3792}