Tanner Industries, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 July 5, 2023 James Klucsarits Manager of Quality and Regulatory Affairs Tanner Industries, Inc. 735 Davisville Road Southampton, PA 18966 Reference No. 22-0118 Dear Mr. Klucsarits: This letter is in response to your October 27, 2022, email pertaining to the use of intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180. In your email, you note that the § 172.101 Hazardous Materials Table lists special provision “IB3” for the proper shipping name “UN2672, Ammonia solutions, relative density between 0.880 and 0.957 at 15 degrees C in water, with more than 10 percent but not more than 35 percent ammonia, 8, PG III.” Special provision IB3 authorizes the following IBCs: Metal (31A, 31B, and 31N); Rigid plastics (31H1 and 31H2); Composite (31HZ1 and 31HA2, 31HB2, 31HN2, 31HD2 and 31HH2). You ask whether a specification 31HA1 composite IBC would be authorized for the transportation of “UN2672, Ammonia solutions, relative density between 0.880 and 0.957 at 15 degrees C in water, with more than 10 percent but not more than 35 percent ammonia, 8, PG III.” The answer is yes. Special provision IB3 lists the letter “Z” as a placeholder rather than listing every possible composite IBC type (HA, HB, HC, etc.). Section 172.102(c)(4) states that the letter “Z” in the marking code for composite IBCs must be replaced with a capital code letter designation found in § 178.702(a)(2) to specify the material used for the other packaging. Therefore, a composite 31HA1 IBC would be authorized under special provision IB3 for your material. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrews 22-0118 From: INFOCNTR (PHMSA) To: Subject: Date: Dodd, Alice (PHMSA); Hazmat Interps FW: Question in regards to Ammonia Solution in Totes Monday, October 31, 2022 4:37:35 PM Attachments: image001.png Hi Alice and team, Please see the LOI request below. Please note that I spoke to this gentleman over the phone before this email was received and he said he wanted to write in for an LOI, however he did not put it in the header. Let me know if anything else is needed. Thanks. -Rachel (HMIC) From: James Klucsarits <jklucsarits@tannerind.com> Sent: Thursday, October 27, 2022 4:59 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Question in regards to Ammonia Solution in Totes CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Hello, My question is in regards to the transportation of ammonia solutions in totes or IBCs. Under special provisions 172.102 it lists IB3 (see below): (8) Packaging (§173.***) (9) Quantity limitations Hazardous materials descriptions and proper shipping names (10) Vessel stowage Hazard class or Division Identification Numbers PG Codes Label Special provisions (§172.102) Exceptions Non- bulk Bulk aircraft/rail Passenger Cargo air- craft only Location Other -1 -2 -3 -4 -5 -6 -7 (8A) (8B) (8C) (9A) (9B) (10A) Ammonia solutions, relative density between 0.880 and 0.957 at 15 degrees C in water, with more than 10 percent but not more than 35 percent ammonia 8 UN2672 III 8 IB3, T7, TP1 154 203 241 5 L 60 L A 40, 85 IB3 Authorized IBCs: Metal (31A, 31B and 31N); Rigid plastics (31H1 and 31H2); Composite (31HZ1 and 31HA2, 31HB2, 31HN2, 31HD2 and 31HH2). My question is why 31HA1 is not listed under Composite (is the Z supposed to be an A?)? Wouldn’t 31HA1 be 31H1 with a steel cage around it? We have a customer trying to supply 31HA1 totes, but that spec is not listed under the regulation. Thanks, James Klucsarits Manager of Quality and Regulatory Affairs Tanner Industries, Inc. (O) (215)-322-1238 ext: 2240 (F) (215)-526-7829 jklucsarits@tannerind.com#