Rossborough Manufacturing Co. — Hazardous Materials Safety Interpretation

Page 1of Transportation US. Department 400 Seventh Street, S.W Washington, D.C. 20590 Research and Special Programs Administration APR 1 6 1999 Mr. Richard S. Varga Ref. No. 99-0061 Rossborough Manufacturing Co. P.o. Box 38 33565 Pin Oak Parkway Avon Lake, OH 44012-0038 Dear Mr. Varga: This is in response to your letter dated March 5, 1999, concerning the definition of "non-DOT specification portable tanks suitable for the transport of liquids." When the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) authorize a "non-DOT specification portable tank suitable for the transport of liquids" any portable tank, as defined in S 171.8, may be used for the transportation of liquids or solids as long as the portable tank meets the general packaging requirements in SS 173.24 and 173.24b. " If the HMR authorize its use, no exemption is required to use a non-DOT specification portable tank. In addition, there are no requirements in the HMR to identify a portable tank as a "non-DOT specification portable tank suitable for the transport of liquids." I hope this satisfies your request. Sincerely, Thomas come A All Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 990061 173.241#

Page 2Gale ROSSBOROUGH MANUFACTURING CO. L.P. $173.241 99-0061 Office of Hazardous Materials Standards Research and Special Programs Administration March 5, 1999 U.S. Department of Transportation 400 Seventh Street, SW Washington, DC 20590-0001 I would like to receive clarification on the regulations. From the Hazardous Material Table, for Calcium, the Bulk Packaging section, column 8C, references §173.241. In this section, paragraph liquids". Please provide clarification to the following questions: c), contains the following, ", and non-DOT specification portable tanks suitable for transport of 1. 2. Define " suitable for transport of liquids"? 3. Can these portable tanks contain solid calcium metal material? 4. Are there any other container or quantity restrictions/requirements? Are any exemptions required for non-DOT specification portable tanks? Do the portable tanks need to be identified as such? is greatly appreciated Please forward the responses to me as soon as possible. Your attention to this clarification Sincerely, Richard S. Varga (1885) Director Quality/Safety Systems P.O. BOX 38 33565 PIN OAK PARKWAY AVONLAKE, OHIO 44012-0038 TEL. (216) 933-9300 CLEVE. (216) 871-6573 FAX (216) 933-4122#