{"operation":"document","citation":"16-0201","title":"EnviroServices & Training Center, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-06-20","effective_on":null,"summary":"16-0201 response to EnviroServices & Training Center, LLC concerning 172.101, 173.12, 176.83, 176.84.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0201.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0201.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0201","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/160201.pdf","body":"<<<PAGE 1>>>\n\nEnviroServices & Training Center, LLC\n505 Ward Avenue, Suite 202\nHonolulu, HI 96814\nReference No. 16-0201\nDear Mr. Perry:\nThis letter is in response to your December 14, 2016, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for lab packs applicable to the\nsegregation requirements exception in § 173.12(e) and the segregation requirements in\n§ 176.83(b). You present a scenario in which a lab pack containing a hydroxide is transported on\na cargo vessel with another lab pack that contains an acid. You note that the hydroxide is\nrequired to be \"separated\" from acids according to the vessel stowage codes in Column 10B of\nthe § 172.101 Hazardous Materials Table (HMT). Specifically, you ask whether § 173.12(e),\nwhich excepts certain waste materials from segregation requirements in § 176.83(b), also\nexcludes these applicable materials from vessel stowage requirements.\nThe answer is no. Column 10B of the HMT refers to other requirements for stowage, cargo\nhandling, and segregation for cargo and passenger vessels in § 176.84. Hazardous materials\noffered for transportation as limited quantities are not subject to the stowage code assigned by\nColumn 10B; however, the same does not apply for items shipped under the lab pack exception\nin § 173.12(b).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nPlease submit this as a letter of interpretation. Mr. Perry spoke with Jodi.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Gregory Perry [mailto:greg@gotoetc.com]\nSent: Wednesday, December 14, 2016 3:28 PM\nTo: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov>\nSubject: Interpretation of 49 CFR Part 173.12(e)\nWhen packing materials in accordance with 173.12(b), the package is exempt from vessel segregation\nrequirements found in 176.83(b) if the package is \"blocked and braced is such a manner that they are separated\nfrom incompatible materials buy a minimum horizontal distance of 1.2 m and the packages are loaded at least\n100 mm of the floor of the freight container, etc.\"\nMy question is: Am I also exempt from vessel stowage codes found in column 10B of the Hazardous Materials\nTable? Specifically code 52.\nSeems inconsistent that I would not be able to ship a labpack of waste containing acid with a labpack of waste\ncontaining a hydroxide which carries a code 52 (stow separated from acids) in column 10B of the HMT but I\ncan be exempt from segregation table requirements in 176.83(b) if a ship other incompatibles in the same\nshipment such as classes 5.1, 4.1, 4.2, 4.3, etc.\nThank you for your response and feel free to contact me directly if you wish to discuss.\nGreg Perry\nEnviroServices & Training Center, LLC\n505 Ward Ave., Suite 202\nHonolulu, HI 96814\nOffice: 808-839-7222\nDirect: 808-664-1934\nWeb: www.gotoetc.com","truncated":false,"body_characters":2953}