OOSC, Part II, Item 3. Bulk Packages/Large Means of Containment, c. Package/Containment Selection

In the HAZMAT portion of the out of service criteria, please define the difference between an unauthorized package versus a specification shortage.

In the out of service criteria, an unauthorized package is to be placed out of service. There is a note that says a specification shortage is not out of service. Unless I’m mistaken, there is no clear list on what is considered an unauthorized package or a specification shortage, besides the easy scenario of being in a cargo tank that is not allowed by the 101 table or an exception.

The cargo tank inspection instructor manual mention several scenarios on when and when not to place a vehicle out of service for an unauthorized package. A cargo tank loaded past its payload is not out of service according to the instructor manual. We know the simple scenario, for example, chlorine gas in a 406, that would be an unauthorized package. Also, for chlorine gas, special provision B9 is listed, which states that bottom outlets are not authorized. I’ve spoken to several cargo tank instructors that have given different answers on whether or not this is an out of service violation or a specification shortage, which means there might be a need for clear guidance. I’ve tried to research a list of what would and would not be considered in an authorized package or a specification shortage, but can’t seem to find the information.