{"operation":"document","citation":"99-0109","title":"Amalgamet Canada — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-08-05","effective_on":null,"summary":"99-0109 response to Amalgamet Canada concerning 173.223.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0109.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0109.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0109","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990109.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n400 Seventh Street, S.W.\nof Transportation\nWashington, D.C.\n20590\nSpecial Programs\nResearch and\nAdministration\nAUG 5 1999\nMr. Raymond Wray\nRef.\nNo.\n99-0109\nAmalgamet Canada\nSuite 418\n111 Richmond St. W.\nToronto, Canada\nM5H 2G4\nDear Mr. Wray:\nThis is in response to your letter dated April 20, 1999,\nregarding the transportation of materials poisonous by inhalation\nin accordance with 49 CFR 173.227 (c). I am sorry for the delay\nand hope this has not caused you any inconvenience.\nIn your letter you ask if the following situation meets the\nconditions of the last sentence of § 173.227 (c):\nI am contemplating a situation where I want to make\ndeliveries of a inhalation hazard (zone B) product to two\ndifferent locations of the same company. The truck would\nstop at one plant, unload the containers for that plant, and\nthen proceed to the second plant (four hours away) where the\nremaining containers would be unloaded.\nThe last sentence of $ 173.227 (C) states that \"shipments must be\nmade from one origin to one destination only without any\nintermediate pickup or delivery.\"\nIt is the opinion of this\noffice that the scenario presented in your letter does not meet\nthe conditions of $ 173.227 (c) because your shipment scenario\ninvolves more than one delivery point.\nI hope this satisfies your request.\nSincerely,\nThor Hall.\nThomas G. Allan\nActing Director\nOffice of Hazardous Materials\nStandards\n173.227\n990109\n\n<<<PAGE 2>>>\n\nAMALGAMET CANADA\nDIVISION OF PREMETALCO INC.\nTORONTO, ONTARIO, CANADA MSH 2G4\n111 RICHMOND ST. W.. SUITE 418\nGale\nTELEX: 06-217726\nTELEPHONE: (416) 366-3954\n§ 173.227\nFAX: (416) 366-0586\n20 April 1999\n99-0109\nU.S. Dept. of Transportation\nResearch and Special Programs Administration\nOffice of Hazardous Materials Standards\n:\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nAttn: Mr. Ed Mazzullo\nI have an interpretation question regarding the last sentence of 49 CFR 173.227(c).\nThis section allows the transportation of containers that do not have secondary overpacks\nif the shipment is from one origin to one destination only without any intermediate pick-up\nor delivery. I am contemplating a situation where I want to make deliveries of a inhalation\nhazard (zone B) product to two different locations of the same company. The truck would\nstop at one plant, unload the containers for that plant, and then proceed to the second plant\n(four hours away) where the remaining containers would be unloaded. At both locations,\npersonnel have good knowledge regarding the hazards and proper handling of these\ncontainers. My question to you is as follows. Is what I have in mind allowed under this\nsection, or do I have to apply for an exemption ?\nIt seems to me that what I have in mind would satisfy the spirit if not the letter of\nthis regulation. It also seems to me that there is nothing to be gained by unloading all of\nthe containers at the first plant, and then loading them onto another truck (perhaps the\nsame truck) so that they can then be delivered to the second plant. I respectfully ask for\nyour opinion on this scenario.\nYours truly,\nRaymond Wray\nManager - Specialty Materials\nANG A MEMBER OF THE AMALCAMATED METAL CORPORATION GROUP","truncated":false,"body_characters":3200}