OOSC, Part III, Item 3. Bulk Packages/Large Means of Containment, e. Leak from Hoses
| Entry Date | April 28, 2021 |
|---|---|
| Issue Number | 21-019-HAZ |
| Name | Daniel Lloyd Voelker |
| Agency | Arizona Department of Public Safety |
| Address | 2102 W Encanto BlvdMail Drop 4011 P.O. Box 6638Phoenix, AZ, 85009United StatesMap It (opens in a new tab) |
| Phone | 9282036772 |
| [email protected] | |
| Committee | Hazardous Materials Committee |
| Status | Closed |
| Summary of Issue | Hose trays, drip trays and product that’s not actively leaking but present. |
| Justification or Need | There has been some discussion in my State that letter of interpretation #150063 is saying we cannot consider the hoses that are not attached to the cargo tank as leaking if we find them to be leaking product. This interpretation is specifically saying that the unattached hoses are not considered part of the package and not required to have closures. For 173.24b1 (leaking HM) to apply it is referring to Hazardous Materials leaking from the package. Obviously, it is not intended to have HM pooled in drip trays or coming out of hoses that are in trays and escaping into the environment. |
| Request for Action | I would like clarification from the CVSA on how pooled HM in drip trays, hose trays, and unattached hoses should be treated during transportation. Is it hazardous materials that are not secure under 177.834? Or does it fall under general cargo of 393.100b? The regulations for 177.834 and 173.24b1 both have the word package in the regulation and the interpretation seems to say those areas are not considered to be a "package". |