Guidanceguidance
98-0313
Hazmat Environmental Group, Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research98-0313
Page 1of Transportation U.S. Department Washington. D.C. 20590 400 Seventh Streel, S.W Research and Administration Special Programs DEC 3 1393 Ms. Nancy J. Copelin Hazmat Environmental Group, Inc. Ref. No. 98-0313 New Village Industrial Park 60 Commerce Drive Buffalo, NY 14218-1040 Dear Ms. Copelin: This is in response to your October 16, 1998 letter concerning the definition of "bulk packaging" as defined in the 49 CFR 171.8. Your question was further clarified in a phone conversation to request a definition of "maximum net mass" which is used to define a bulk packaging. Your understanding is correct. If your receptacle is rated to hold more than 400 kg (882 pounds) and has a maximum net capacity greater than 450 I (119 gallons) then your receptacle is considered a bulk packaging even if your receptacle weighs less than 400 kg (882 pounds) at the time of shipment. The bulk packaging definition is based on the capacity of your receptacle, not on the actual amount contained therein at the time of shipment. I hope this satisfies your request. Sincerely, / Transportation Regulations Specialist Office of Hazardous Materials Standards#
Page 298-0313 BAH HAZMAT $ 171•8 Bolk Pke I HOUPINENTAL New Village Industrial Park GROUP, INC. Buffalo, New York 14218-1040 60 Commerce Drive HAZARDOUS MATERIALS SERVICES... TRANSPORTATION....TRAINING... CONSULTING Permitted In 48 States and Canada Phone: (716) 827-7200 Fax: (716) 827-7217 www.hazmatinc.com October 16, 1998 Ed Mazzullo, Director CERTIFIED NO.: P518920778 Office of Hazardous Materials Standards DOT/RSPA 400 7* Street SW Mail Stop DHMI-10 Washington, D.C. 20590 Dear Mr. Mazzullo: The purpose of this correspondence is to request written clarification of the definition for "bulk packaging" as defined in 49 CFR 171.8(2) as a receptacle for a solid. My understanding is that a solid receptacle with a maximum capacity greater than 450 L (119 gallons) that is also capable of weighing more than 400 kg (882 pounds) but may actually weigh less than 882 pounds at the time of shipment is considered a bulk package. If you have any questions regarding this matter, please contact me at (716) 827-7200. I appre- ciate your assistance. Sincerely, Vancy J. Copéli Director of Compliance cc: D. Dintino#
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